Ninth Circuit Narrowly Reads Section 506(d) on Voiding Liens After Claim Disallowance
A claim must be disallowed based on the invalidity of the debt before the associated lien can be voided under Section 506(d), the Ninth Circuit ruled in upholding the BAP.
Seventh Circuit Requires Chapter 13 Payments Beyond Five Years
Appeals court narrowly reads Bullard on finality.