Business Reorganization

‘Preserved’ Liens Can Sometimes Be Worthless, Ninth Circuit Says

When a lien is undersecured, the avoided portion of the lien takes nothing through preservation until the unavoidable portion of the lien is paid in full.
Court: 

Chapter 11 Plan May Impair a Mortgage When the Debtor Is Not Liable on the Debt

A chapter 11 plan may not impair the rights of a mortgage lender against a co-owner who is not in bankruptcy.

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