Michelle H. Bass’s article “Fail to Make Direct Payments to Secured Creditors? No Discharge!” was published in the May 2019 edition of the American Bankruptcy Institute Journal. The article explores the emerging trend for bankruptcy courts to deny a consumer’s discharge where the individual failed to make all required payments under the plan. The recent string of opinions examined highlights the potential harsh reality for consumers who may unknowingly forfeit their discharge over missed payments on a secured claim.
