It is a common misunderstanding that a debtor can send a check which either has written on it or accompanying it a payment plan or terms and the statement that "by cashing this check, you accept these terms" and thereby create a binding agreement. This is not true.To create an agreement, there must be offer, acceptance, and consideration--something given, which binds the agreement. The problem is, if there is already an obligation to give that money or that item, etc., then you cannot be given as consideration--the other party *already* has a right to it, so they are getting nothing new. If you are already obligated to apy a debt, any payments you make toward that debt go to an *existing* obligation; they cannot serve as consideration for a new agreement.There is no way to make a creditor accept a repayment plan; accepting a plan requires the creditor's voluntary agreement to it.