摘要：Surely the two most important secured lenders in chapter 13 bankruptcy cases
are the home mortgage lender and the car lender. The home mortgage lender was
quite well protected from adverse treatment in chapter 13 plans prior to the massive
2005 amendments to the Bankruptcy Code. Basically, these loans cannot be
"crammed down"¡ªthat is, rewritten according to the strictures of Bankruptcy Code
section 1325(b)(5).1 Rather, the mortgage agreement must be reinstated going
forward, with defaults cured within a "reasonable time."2
