When the court determines the value, as of the effective date of a plan, of property to be distributed under a plan for any confirmation purpose, it will presume the appropriate interest rate to be paid to a creditor secured by the property is the national average of the prime rate published in The Wall Street Journal on the last day before the confirmation hearing, stated as a simple interest rate per annum, plus two percentage points. See Till v. SCS Credit Corp., 124 S. Ct. 1951 (2004). A creditor desiring a different interest rate must object to confirmation based on the inadequacy of the rate. The creditor has the burden of proof by a preponderance of the evidence on the appropriate interest rate. A Chapter 13 plan must state the specific interest rate to be paid to a creditor.
Part III. Claims and Distribution to Creditors and Equity Interest Holders; Plans