I appeared before US Bankruptcy Judge Glenn this week in New York’s Southern District at the confirmation hearing of a Chapter 13 plan. The plan was confirmed (approved). It provided for at least 9% to be paid to unsecured creditors over 36 months, which was more than they would have received in a “hypothetical chapter 7 liquidation.” My client had over $100,000 in credit card debt. Because the bar date had not yet run and it was not clear if all claims had been filed, it is possible that the percentage distribution may end up higher than 9%, although that will have no impact on my client’s monthly payment to her trustee. The 36 month term was determined by the Statement of Current Monthly Income Form B22C (also called the Means Test by attorneys and trustees). We were all very pleased with the outcome.