The Appropriate Interest Rate Under ' 506(b)

We all know what the issue is. Section 506(b) of the Bankruptcy Code provides that over-secured creditors are entitled to receive post-petition interest, but it does not tell us what interest rate should be applied. Aye, there's the rub. Indeed, Congress' failure to provide the appropriate interest rate has triggered numerous disputes in many different jurisdictions as to whether: 1) the appropriate rate should be the contract rate, the Federal judgment rate, or some other rate altogether; and 2) regardless of which rate is selected, will the award of post-petition interest harm other creditors? This article explores the specific facts and circumstances that Judge Glenn considered and ultimately relied upon when deciding to rule in favor of Citibank, playing the role of secured creditor in the case, granting, for the most part, its request to receive post-petition interest at the default rate governed by its contract.