Chapter 13 bankruptcy requires that there be a showing of a post-confirmation “substantial and unanticipated change in circumstances” to upset the res judicata Confirmation Order. This would preclude a Trustee from seeking a modification based on the surrender or successful strip-off o a house, since these are preconfirmation issues/changes. This could leave the Trustee hunting for some other change in circumstances, but he’s still got to find one and show that it is substantial and unanticipated. Other Circuits, however, have a much lower standard for modification under 1329. That said, modification under 1329 is still just for post-confirmation changes, so even these lower standards shouldn’t pull the strip-off or surrender of property in. So in other words, the res judicata effect of the plan order, coupled with the requirement under 1329 that a creditor file a motion to modify, will preclude any creditor from claiming money is owed at the end of the term of the plan. If a creditor were to wait for the very end of the plan, even showing a change that occurred the day after confirmation, you could likely raise the defense of laches, namely that they delayed too long.