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163 proper interest rate is the federal judgment rate, while others have indicated that the contract rate should be applied. Compare In re Ultra Petroleum Corp., 913 F.3d 533 (5th Cir. 2019) (applying the contrat default rate); with In re PG&E Corp. Dkt. No. 5226 (Memorandum Decision), No. 19-30088 (Bankr. N.D. Cal. Dec. 30, 2019) (applying the federal judgment rate). 6. Chapter 11 Liquidating Plans In some cases, a Chapter 11 plan may provide for the liquidation of a debtor's business. Proponents of a Chapter 11 liquidating plan must still satisfy the requirements of Section 1123 of the Bankruptcy Code described above, as well as the confirmation requirements discussed below in Chapter VI.G. Among the requirements for confirmation of a plan is that administrative priority claims and certain other priority claims be paid in full. 11 U.S.C. § 1129(a)(9). Thus, the plan proponent must ensure that sufficient funds will be available to satisfy certain claims, including all administrative expense claims and certain unsecured priority claims (discussed in greater detail below). Otherwise, the case will be deemed "administratively insolvent" and will likely be converted to Chapter 7. Businesses often prefer to liquidate their assets under Chapter 11 (as opposed to Chapter 7) because it allows the existing management to remain in place, which arguably allows a more orderly liquidation to take place, thus increasing the ultimate return to creditors. 7. Modification of a Plan Proponents of a plan will sometimes be faced with unanticipated circumstances subsequent to the solicitation of votes on, or even confirmation of, such plan. In certain situations, this may require modification of the plan. Section 1127 of the Bankruptcy Code provides certain requirements plan proponents must meet if they wish to modify the terms of a plan. First, the Holdings Corp., 540 B.R. 109, 124 (Bankr. D. Del. 2015); In re Ultra Petroleum Corp., No. 16-32202, 2017 WL 4863015, at *15 (Bankr. S.D. Tex. Oct. 26, 2017).

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