yes, hency my statement about a bankrupt who can afford it.
HOWEVER, an adversary is not always needed (at least pre2005) if you had a lender who was willing to negotiate and see the futility of their position.
What I have seen of late is lenders who have no clue about business and are in a “screw everyone” mindset.
While the 2005 reform only managed to increase ch13’s very slightly, I think the trend to more plans than liquidation is going to force trustees to get into the stripping mix in order to preserve the income source for the other creditors.
The Trustees are so overloaded that it would require some new case law to mandate such actions, IMHO.