Issue link: https://mbozikis.ufcontent.com/i/1422521
158 day periods referenced in clauses (ii) and (iii), respectively, can be reduced or increased for cause by the court. 11 U.S.C. § 1121(d)(1). However, the 120-day period cannot be extended beyond a date that is eighteen months after the date of the order for relief, and the 180-day period cannot be extended beyond a date that is twenty months after the date of the order for relief. 11 U.S.C. § 1121(d)(2). Once the debtor's exclusive period ends, any party in interest may propose a plan, including the debtor, the trustee, a creditors' committee, an equity security holders' committee, a creditor, an equity security holder or an indenture trustee. 11 U.S.C. § 1121(c). 2. Classification of Claims and Interests When formulating a Chapter 11 plan, the plan proponent is required to divide the various holders of claims and equity interests into different groupings or "classes." These classes are generally organized by type of claim or interest. In particular, a plan may only classify a claim or an interest in a particular class if such claim or interest is substantially similar to the other claims or interests comprising such class. 11 U.S.C. § 1122(a). A plan, however, may designate a separate class of claims consisting only of those unsecured claims that are less than or reduced to an amount approved by the bankruptcy court as reasonable and necessary for administrative convenience. 11 U.S.C. § 1122(b). Such a class is commonly referred to as a "convenience class." Additionally, although the Bankruptcy Code does not expressly prohibit the separate classification of similar claims, a debtor may not separately classify claims solely to obtain the vote of an impaired, assenting class. Instead, the debtor has the discretion to classify claims separately only where there are "significant disparities" between the legal rights of the holders of different claims or if there are "good business reasons" for doing so. In re Wabash Valley Power Ass'n, 72 F.3d 1305 (7th Cir. 1995); see also In re Loop 76, LLC, 465 B.R. 525 (B.A.P. 9th Cir. 2012) (upholding bankruptcy court determination in single-asset real estate case that a secured lender's unsecured deficiency claim