to pay entities that held senior-lien notes: [2]-Although use of a formula approach was approved by a plurality of the U.S. Supreme Court in Till v. SCS Credit Corp., Till did not preclude use of a market rate approach, and use of a market rate approach was preferable in cases where an efficient market existed;

ns > Plans > Confirmation > Cramdowns [HN8] Many courts have relied on footnote 14 of the United States Supreme Courts plurality opinion in Till v. SCS Credit Corp. to conclude that efficient market rates for cramdown loans cannot be ignored in Chapter 11 bankruptcy cases. Most notably, in In re American HomePa

Debtors defend the application of the "formula" method on the ground that it is required by the plurality opinion in the Chapter 13 case of Till v. SCS Credit Corp., 541 U.S. 465, 124 S. Ct. 1951, 158 L. Ed. 2d 787 (2004). The Senior-Lien Notes holders contend that because this rate is too low, the Plan is not

izations > Plans > Confirmation > Cramdowns [HN7] The "formula" approach endorsed by a plurality of United States Supreme Court Justices in Till v. SCS Credit Corp. for determining an appropriate rate of interest when a creditor's claim is crammed down instructs bankruptcy courts to begin with a largely risk- fr