Waldron v. Brown (In re Waldron), 536 F.3d 1239, 1245 (11th Cir. 2008) (Edmondson, Pryor, Johnson) (Bankruptcy court has discretion to require disclosure of postpetition causes of action, including recovery from uninsured motorist insurance, consistent with creditors’ rights under § 1329. “The disclosure of postconfirmation assets gives the trustee and creditors a meaningful right to request, under section 1329, a modification of the debtor’s plan to pay his creditors. . . . When a debtor discloses assets acquired after confirmation, creditors may move the bankruptcy court to modify the plan to increase payments made by the debtor to satisfy a larger percentage of the creditors’ claims. . . . We do not hold that a debtor has a freestanding duty to disclose the acquisition of any property interest after the confirmation of his plan under Chapter 13. Neither the Bankruptcy Code nor the Bankruptcy Rules mention such a duty, cf. Fed. R. Bankr. P. 1007(h) (requiring a debtor to supplement his schedule regarding interests acquired after petition under section 541(a)(5) of the Code), and our precedents . . . do not address that issue. But the bankruptcy court has the discretion, under Rule 1009, to require a debtor to amend his schedule of assets to disclose a new property interest acquired after the confirmation of the debtor’s plan.”).

See Also: Chapter 7 Bankruptcy