Bank of America, N.A. v. Bello
Petition granted, judgment vacated and case remanded for further consideration in light of Bank of America, N. A. v. Caulkett on June 8, 2015.
Issue: Whether, under Section 506(d) of the Bankruptcy Code, which provides that “[t]o the extent that a lien secures a claim against the debtor that is not an allowed secured claim, such lien is void,” a chapter 7 debtor may “strip off” a junior mortgage lien in its entirety when the outstanding debt owed to a senior lienholder exceeds the current value of the collateral.