disbursements made by the debtors;. the Fifth Circuit noted that "outside the plan” had greater significance under the pre-Code Bankruptcy Act, because secured creditors whose claims were dealt with by a plan were entitled to vote — therefore, stating that payments to a secured creditor were being made "outside the plan” might eliminate the secured creditor’s right to vote on the plan; the Fifth Circuit held that it is permissible for Chapter 13 debtors to make plan payments directly to a mortgage lender, in connection with curing and maintaining a mortgage, but when they do, it is still considered payments “under the plan ” ). 20 . Kessler, 2015 WL 4726794 at *3 (citing In re Harris, 107 B.R. 204, 208 (Bankr.D.Neb.1989)); see also In re Heinzle, 511 B.R. 69, 78 (Bankr.W.D.Tex.2014) (<HOLDING>). 21 . Id. at 78. 22 . 11 U.S.C. § 1329(c). 23
holding that a plan provision stating that the summary plan description and summaries of material modifications  are hereby incorporated by reference and constitute a part of the plan acted to incorporate into the plan a limitations provision found only in the summary plan description holding that a payment is under the plan when the debt is provided for in the plan holding that professionals who advised the plan were not fiduciaries because they had no decision making authority over the plan or plan assets also noting that the power to act for the plan is essential to status as a fiduciary holding that although the plan cannot discharge the debt  the claimant may otherwise subject the debt to the provisions of a confirmed plan holding that plan language giving plan administrator power to determine which employees are eligible to participate in the plan and providing all parties dealing with the plan an interpretation of plan provisions on request indicates deferential standard of review of trustee eligibility decisions