NACBA has filed an amicus brief in the case of In re Frederickson pending in the Eighth Circuit Court of Appeals.  In a split decision, the Bankruptcy Appellate Panel held that above-median debtors with disposable income of zero or less were not required to propose a 60-month plan.  NACBA's brief agrees with the majority and argues that were debtors have no disposable income, the applicable commitment period is irrelevant.