Section 1192 -- Subchapter V Cramdown

Nonconsensual plan confirmation. The projected disposable income test and how it differs from Chapter 13.

What Is Section 1192?

Section 1192 defines the cramdown requirements for Subchapter V. When a plan cannot be confirmed consensually because impaired classes reject it, the court may confirm under 1191(b) if Section 1192 requirements are met.

The central requirement: commit all projected disposable income for 3-5 years.

Projected Disposable Income

Income not reasonably necessary for:

Key difference from Chapter 13: Uses actual projected income and reasonable expenses -- not the mechanical IRS standards of the means test.

Fair and Equitable Requirement

The plan must not discriminate unfairly and must meet the disposable income test.

No absolute priority rule: The debtor may retain equity even if unsecured creditors are not paid in full.

Discharge Comparison

PathWhenScope
1191(a) ConsensualUpon confirmationBroad (standard Ch. 11)
1191(b)/1192 CramdownAfter all paymentsNarrower -- 523(a) exceptions apply

Important: Under cramdown, debts for fraud, willful injury, domestic support, taxes, and student loans survive discharge.

Related Resources

section1191.org -- Consensual confirmation

523a.org -- Exceptions to discharge

1328f.org -- Bankruptcy research platform

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