Issue link: https://mbozikis.ufcontent.com/i/1422521
208 debtor's plan and the amount of payments to unsecured creditors under such plan. Additionally, any individual seeking relief under Chapter 13 must have received from an approved nonprofit budget and credit counseling agency an individual or group briefing that outlines the opportunities available for credit counseling and assistance in performing a related budget analysis. Each of these must have occurred in the 180 days preceding the filing of the individual's Chapter 13 petition. 11 U.S.C. § 109(h). Notwithstanding the foregoing, no individual may be a debtor under Chapter 13 if such individual has been a debtor under any Chapter of the Bankruptcy Code in the preceding 180 days and (i) the case was dismissed by the court for the debtor's willful failure to abide by court orders or to appear before the court in proper prosecution of the case or (ii) the debtor requested and obtained the voluntary dismissal of the case after a request for relief from the automatic stay was filed in such case. 11 U.S.C. § 109(g). C. Automatic Stay Under Chapter 13, once the automatic stay is in place, creditors are precluded from taking action to collect a consumer debt 116 against an individual, or the property of such individual, who is also liable for that debt unless such individual became liable on or secured the debt in the ordinary course of his business or if the case is closed, dismissed or converted to Chapter 7 or 11. 11 U.S.C. § 1301(a). This provision is designed to insulate the Chapter 13 debtor from any pressures his creditors may attempt to exert through friends or relatives that have cosigned any of the debtor's obligations. On request of a party in interest, and after notice and a hearing, relief from the codebtor stay shall be granted to the extent that (i) the codebtor received the consideration for the debt, (ii) the Chapter 13 plan proposes not to pay such debt or (iii) the creditor's interest would be irreparably harmed by continuation of the codebtor stay under clause (ii) above. 11 U.S.C. § 1301(c). 116 The Bankruptcy Code defines a "consumer debt" as a "debt incurred by an individual primarily for a personal, family or household purpose." 11 U.S.C. § 101(8).