In this context, I also think the foreclosure standard best comports with economic reality. Allowing any more than the foreclosure value simply grants a general windfall to undersecured creditors at the expense of unsecured creditors. As Judge Easterbrook explained in rejecting the split the difference approach as a general rule, see id. , at 318-320, a foreclosure value standard is also consistent with the larger statutory scheme by keeping the respective recoveries of secured and unsecured creditors the same throughout the various bankruptcy chapters. Accordingly, I respectfully dissent. Ante , at 8.
Present value includes both the underlying value and the time value of that interest.
The time value component similarly vitiates the risk concern. Higher risk uses of money must pay a higher premium to offset the same opportunity cost.