According to Robing Miller of CBAR, under Illinois law, a quitclaim deed given to the mortgage lender by the debtor prepetition in connection with a forbearance agreement was treated as an equitable mortgage rather than as a conveyance of the property. As a result, the debtor remained the owner of the property and could include the mortgage debt in her Chapter 13 plan.
In re Primes, 518 B.R. 466 (Bankr. N.D. Ill., Sept. 26, 2014)
(case no. 3:13-bk-83310) (Bankruptcy Judge Thomas M. Lynch)