In re Pearson, 10 B.R. 189, 192 (Bkrtcy.E.D.N.Y.1981). 9 . A number of courts have noted the basic policies of financial rehabilitation and relief without liquidation found in Chapter 13. Those courts have also noted that Chapter 13 should be construed liberally to effect those policies. Courts have also acknowledged that these liberal policies may result in a delay in the enforcement of, or impairment of, secured creditors’ claims, including claims of mortgagees. See, e.g., In re Freed & Co., 534 F.2d 1235, 1239 (6th Cir.1976); Hallenbeck v. Penn Mutual Life Ins., 323 F.2d 566 (4th Cir.1963) (bankruptcy courts can enjoin the foreclosure of a mortgage on a debtor’s residence); see also Continental Ill. Bank v. Chicago R.I. & P. Ry., 294 U.S. 648, 55 S.Ct. 595, 79 L.Ed. 1110 (1935) (<HOLDING>). 10 . As both parties readily admit, Chapter
holding that in contrast to foreclosure of a mortgage secured by personal property foreclosure of real property under a deed of trust need hot be at a commercially reasonable sale and the failure to conduct a commercially reasonable foreclosure sale of real property is not actionable holding an unsecured creditors postconfirmation suit against a secured creditor for fraudulent misrepresentation at a creditors meeting constituted a collateral attack on the confirmation order holding that the secured creditor was only entitled to the amount of its claim as provided in the debtors chapter 13 plan when the destruction of the vehicle yielded insurance proceeds greater than the secured creditors claim holding impairment of secured creditors foreclosure remedy permissible holding that a failure to comply with the foreclosure statutes invalidates a foreclosure sale