In chapter 13s, the plan – the preprinted plan form – says the debtor will pay x amount per month “which is estimated to pay unsecured creditors x% over the plan period” (paraphrasing the quote). There is a recent crazy BAP case, In re Schlegel, that says the debtor is promising, per the form, to pay the percentage to unsecured creditors, not just the amount specified. So if a proof of claim is filed after the plan is confirmed, the debtor must object or amend his plan to change the percentage in the plan. Assuming there is no basis to object, it is a complete waste of time if you ask me to amend the plan just to change the percentage. Anyway, I was explaining this to one of the associates here and it occurred to me that the chapter 11 plan for an individual should include language that the debtor is not promising to pay some specific percentage to unsecured unsecured creditors, only some specific amount to the class as a whole.