Key takeaways 

• The United States Court of Appeals for the Seventh Circuit, in In re River Road Hotel Partners, LLC, ruled that a plan of reorganization providing for a sale of encumbered assets but denying secured creditors the right to credit bid on such assets may not be confirmed over the objection of secured creditors. 
• The Seventh Circuit’s holding represents a significant shift in precedent, after prior Third and Fifth Circuit decisions established a trend limiting a secured creditor’s right to credit bid in a cramdown plan.