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Smart Summary

Factual and Procedural Background

In this Chapter 13 bankruptcy case, the standing trustee moved under 11 U.S.C. § 502(j) and Federal Rules of Bankruptcy Procedure 3008 and 9006 to reconsider and disallow FinWise Bank’s allowed claim. [1][2] The trustee reported that distributions mailed to the address on the proof of claim were returned as undeliverable and that FinWise Bank did not provide a corrected address despite multiple requests. [3][4] The trustee sought disallowance so the accumulated funds could be distributed to other creditors. [4]

Legal Issues Presented

  1. Whether a claim that was “deemed allowed” by filing, but was not allowed by court order, may be reconsidered and disallowed under 11 U.S.C. § 502(j) and Federal Rule of Bankruptcy Procedure 3008. [5][6]
  2. Whether a creditor’s failure to update its mailing address constitutes a statutory basis for disallowing its claim. [5][7][8]
  3. What remedy applies to distributions that cannot be delivered to the creditor. [9][8]

Arguments of the Parties

Trustee’s Arguments

  • The trustee sought reconsideration and disallowance of FinWise Bank’s claim because distributions sent to the claim address were returned and the creditor failed to provide a corrected address. [2][4]
  • The trustee relied on the language of § 502(j) allowing a reconsidered claim to be allowed or disallowed “according to the equities of the case,” suggesting that the court had broad equitable discretion to disallow the claim. [5][10]

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

A filed proof of claim is deemed allowed unless a party in interest objects. If an objection is filed, § 502(b) requires the court to determine the claim under applicable nonbankruptcy law and allows it unless a statutory exception applies. The court therefore rejected the idea that it had unrestricted equitable discretion to disallow claims. [4][11][12][13]

The court explained that § 502(b) provides the exclusive grounds for disallowance when an objection is filed, and failure to update a mailing address is not one of those grounds. That failure does not invalidate the claim or trigger a statutory exception to allowance. [5]

The trustee, however, had not filed an objection; he had moved for reconsideration. The court held that § 502(j) does not apply to a claim that is merely deemed allowed, because such a claim has not previously been reviewed or considered by the court. [5][14][15]

Rule 3008 confirms this conclusion by authorizing a motion to reconsider an order allowing or disallowing a claim. Because no order allowed FinWise Bank’s claim, there was nothing to reconsider. Applying Rule 3008 to a deemed-allowed claim would improperly circumvent the statutory limits in § 502(b). [7]

The court acknowledged the trustee’s frustration but determined that Congress had supplied a specific remedy for undeliverable distributions. Under § 347(a), returned payments must be deposited into the court’s unclaimed-funds registry, where they remain available for the creditor to claim. [9][8]

Holding and Implications

THE MOTION TO RECONSIDER AND DISALLOW CLAIM WAS DENIED. The court held that § 502(j) and Rule 3008 did not apply because no order allowing the claim existed, and the creditor’s failure to update its address was not a basis for disallowance under § 502(b). [8]

The trustee must deposit undeliverable distributions into the court’s unclaimed-funds registry under § 347(a), rather than disallowing the claim. [8] The opinion identifies no broader implications or new precedent; its direct effect is to preserve the creditor’s claim and require the trustee to use the statutory unclaimed-funds procedure.

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Christaphor John Masiclat

1

UNITED STATES BANKRUPTCY COURT

DISTRICT OF HAWAII

In re:

CHRISTAPHOR JOHN

MASICLAT,

Debtor. Case No.: 23-00211 Chapter 13

Related: ECF 39

ORDER REGARDING TRUSTEE'S MOTION TO

RECONSIDER AND DISALLOW CLAIM

The standing chapter 13 trustee moves under 11 U.S.C. § 502(j) and Fed. R. Bankr. P. 3008 and 9006 to reconsider and disallow an allowed claim held by FinWise Bank ("Creditor").

The trustee states that all distributions mailed to the address on the Creditor's proof of claim were returned as undeliverable, and that the

Date Signed:

May 6, 2026

2

Creditor has not provided a corrected address despite multiple requests. On November 17, 2025, the trustee instructed the Creditor to file corrected change-of-address forms within 30 days and stated that failure to comply would result in a section 502(j) motion or deposit of the undeliverable amounts into the court's unclaimed funds registry. The Creditor did not file a corrected address. The trustee now seeks disallowance so the accumulated funds may be distributed to other creditors. The trustee has chosen an inapplicable procedural basis for his request. If a creditor files a proof of claim, the claim is "deemed allowed"

unless a party in interest objects to the claim.1If a party files an objection, the court must determine the amount of the claim under applicable nonbankruptcy law and allow the claim in that amount unless certain exceptions apply.2In other words, the bankruptcy court does not have unfettered discretion to disallow claims based on generalized notions of equity.

1 1 1 U.S.C. § 502(a).

2 11 U.S.C. § 502 (b).

3

If the trustee had filed an objection to the claim, the trustee would have lost. Section 502(b) provides the exclusive grounds for disallowance, and a creditor's failure to update its mailing address is not among them. A creditor's failure to provide an updated mailing address does not invalidate the creditor's claim under applicable nonbankruptcy law and does not invoke any of the statutory exceptions to allowance. But the trustee did not file an objection to the claim. Instead, he filed a motion for reconsideration of the allowance of the claim. This position is based on the premise that the trustee seeks "reconsideration" of the

"deemed allow[ance]" of the claim. This position arguably benefits the trustee because section 502(j) provides that, if the court finds "cause" to reconsider the claim, "the reconsidered claim may be allowed or disallowed according to the equities of the case." The trustee suggests that this language gives the court broad discretion to disallow the claim on any equitable ground.

Read carefully, section 502(j) does not apply to a claim that is only

"deemed allowed." The section speaks of "reconsideration" of a claim. But

4

a claim is deemed allowed simply by being filed, without any court review or consideration. It makes no sense to "reconsider" a claim that the court has never "considered" in the first place.

Rule 3008, which implements section 502(j), makes this clear. The rule authorizes parties in interest to "move to reconsider an order allowing or disallowing a claim."3Because there is no order allowing the Creditor's claim, there is nothing to reconsider under section 502(j) or Rule 3008. Allowing Rule 3008 to disallow a "deemed allowed" claim would make irrelevant the carefully drawn provisions of section 502(b). Parties in interest could always argue that the court should disallow a "deemed allowed" claims on equitable grounds, even though none of the exceptions of section 502(b) apply.

The trustee's frustration with the Creditor's unresponsiveness is understandable. But Congress has provided a specific mechanism for undeliverable distributions. Under section 347(a), when a distribution cannot be delivered, the trustee must deposit the returned payments into

3 Fed. R. Bankr. P. 3 008.

5

the court's unclaimed funds registry. These funds do not escheat and remain available indefinitely for the creditor to claim.4Unless and until Congress enacts a different statutory scheme, this is the sole remedy for a creditor's failure to provide a current address for distributions. Because section 502(j) and Rule 3008 do not apply in the absence of an order, and because the Creditor's failure to update its address does not render its claim unenforceable or otherwise disallowable under section 502(b), the trustee's Motion to Reconsider and Disallow Claim is DENIED. The trustee shall deposit any undeliverable distributions into the court's unclaimed funds registry pursuant to section 347(a).

END OF ORDER

4 28 U.S.C. § 204 1 provides for the deposit of unclaimed funds "in the name and to the credit" of the court. No money deposited under section 2041 can be withdrawn except by order of court. 28 U.S.C. § 2042.

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Comments

Christaphor John Masiclat
(May 6, 2026)