An oversecured creditor is entitled to interest on the debt between the date the petition is filed and a reorganization plan is approved.  If the debt obligation provides for a default rate of interest, that interest rate applies during the petition-to-plan period so long as (a) the security is sufficient to pay it, (b) the interest rate is enforceable under applicable non-bankruptcy law, and (c) equitable factors do not counsel against application of that interest rate.  Here, the bankruptcy court disallowed the default interest rate without applying the foregoing test, so its order is reversed for reconsideration under the proper test.

Ninth Circuit Court of Appeals Bankruptcy Appellate Panel (Kirscher, J.); March 31, 2016; 2016 WL 1357583