Task: Text Completion
Input (English): Moreover, under the present law, the Debtor will not receive a discharge unless he completes performance of the Plan. 11 U.S.C. § 1141(d)(5). Thus, if the Debtor were unable to perform the Plan, Osh-untola would suffer little prejudice from its having been confirmed. 4 . The Court does not read 11 U.S.C. § 108 as extending this period. 5 . Oshuntola did not object to confirmation on this ground. However, the Court has an independent duty to confirm a plan only if satisfies the requirements of the Bankruptcy Code. In re Great Northwest Recreation Center, Inc., 74 B.R. 846, 852 (Bankr.D.Mont.1987). 6 . Courts differed as to whether an individual debtor could retain exempt property without violating the "absolute priority” rule. See In re Bullard, 358 B.R. 541, 544-45 (Bankr.D.Conn.2007)(<HOLDING>). 7 .The modification concludes with the phrase 
 Holding statements: (A) holding that spouse could not claim exemption in property that was only property of other spouses estate (B) holding that because property was no longer property of the estate the court could not order turnover (C) holding that the mortgaging or conveying of exempt property to a creditor is not against the public policy of the state of michigan and that that the bankrupt had the power to convey to a creditor his existing exemptions resulting in the exempt property not being property of the debtor or the debtors bankruptcy estate (D) holding that the debtor could retain exempt property because it was not property of the estate (E) recognizing that exempt property ceases to be property of the estate
Output (English): (D)