Fridley v. Forsythe (In re Fridley), 380 B.R. 538, 543 (B.A.P. 9th Cir. 2007) (Klein, Montali, Jury) (Although Sunahara v. Burchard (In re Sunahara), 326 B.R. 768 (B.A.P. 9th Cir. 2005), permitted prepayment of confirmed plan, modification motion is required before debtor may prepay plan and obtain early discharge, unless prepayment satisfies all allowed claims. Construing § 1325(b) “applicable commitment period” as temporal requirement, confirmation of plan providing 36 months of disposable income required debtor to either continue to pay for full 36 months or move for modification under § 1329. Debtors may not obtain early discharge under § 1328(a) without modifying. “Sunahara did not inadvertently license circumvention of § 1325(b) by the ploy of confirming a plan that complies with § 1325(b) and then promptly modifying the plan in a manner that does not comply with § 1325(b). Such a stratagem plainly would be an unfair manipulation of the Bankruptcy Code.” Enactment of BAPCPA did not change requirement of modification, and debtors have not satisfied §§ 1328(a)and 1329(b) requirements for plan completion by prepayment without modification.).

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