As reported by Robin Miller of CBAR, the Till rate is proper interest rate for 910-day-car claim in Chapter 13 plan.
While the hanging paragraph added by BAPCPA to Code § 1325(a) prevents a 910-day-car claim from being stripped down to the value of the motor vehicle securing the claim, this did not prevent a Chapter 13 plan from modifying a creditor’s 910-day-car claim in other ways, such as by reducing the interest rate payable on the claim from the rate called for in the parties’ contract, and the Till rate was the proper interest rate where the creditor did not present any evidence that 2% was an inappropriate risk adjustment to the 3.25% prime rate.
In re Kemmery, 516 B.R. 485 (Bankr. N.D. Ohio, Sept. 17, 2014)
(case no. 5:14-bk-50999) (Bankruptcy Judge Alan M. Koschik)