Order Overruling Objection to Claim. The Debtors objected to the secured claim filed by U.S. Bank for a debt which arose out of a home equity line of credit ("HELOC"). The HELOC was secured by a deed of trust on the Debtors' residential real property. The Debtors contended that the claim amount did not accurately reflect all the Debtors' payments to U.S. Bank from November 2008 through June 2013, and showed an improper application of payments made between 2013 and 2022 because there was only a negligible decrease in the principal balance in that period.
     The Court first reviewed the procedural rules and evidentiary principles involved in resolving claim objections. Under Federal Rule of Bankruptcy Procedure 3001(f), a proof of claim filed in accordance with the requirements of Rule 3001 is treated as prima facie evidence of the validity and amount of the claim. Among these requirements, the proof of claim must be filed in writing and conform to the Official Form, as well as include certain specific documentation depending on the type of claim. While the holder of the claim has the ultimate burden of proof respecting its allowance, a claim to which the presumption of validity has attached shifts the burden of production to the objecting party, who must “produce evidence sufficient to negate the prima facie validity and amount of the claim.” In re Wright, 438 B.R. 550, 553 (Bankr. M.D.N.C. 2010). The amount of evidence necessary to rebut a presumption will vary depending on such factors as the policy reasons for favoring the presumption and the strength of the evidence supporting the presumption, but in all cases, the objector must produce actual evidence, not mere allegations without evidentiary support. Bankruptcy Evidence Manual § 301:4 (2022 ed.); In re F-Squared Inv. Mgmt., LLC, 546 B.R. 538, 544 (Bankr. D. Del. 2016). A debtor’s testimony on its own may be enough to defeat a claim that lacks presumptive validity; however, where a claim is treated as presumptively valid, objections relying solely upon testimony from debtors without additional documentation and evidentiary support are less likely to find success.
     The Court determined that U.S. Bank’s claim and its attachments contained all the information required by Rule 3001 and was presumptively valid, shifting the burden to the Debtors to rebut the presumption. The Debtors, however, only introduced evidence in the form of the male Debtor’s unsupported testimony. With respect to payments made between 2008 and 2013, the parties did not dispute that the Debtors made regular monthly payments during that period. However, the Debtor’s testimony was not sufficient to rebut the presumption that the principal balance asserted at the end of that period was correct because of the HELOC’s repayment provisions, which created a separate “draw period” and “repayment period.” With respect to payments made between 2013 and 2022, the Court again found the Debtor’s testimony was insufficient to rebut the presumption that the payments were applied properly to interest and fees rather than principal. These payments were made through the Debtors’ two prior bankruptcy cases, which were both dismissed and “return[ed] the parties to the positions they were in before the case was initiated.” Wells Fargo Bank, N.A. v. Oparaji (In re Oparaji), 698 F.3d 231, 238 (5th Cir. 2012). Thus, U.S. Bank was allowed to recalculate the payments received in accordance with the original mortgage contract, as if the bankruptcy cases had not occurred. In re Carlton, 437 B.R. 412, 418 n.7 (Bankr. N.D. Ala. 2010). The Debtors did not provide evidence sufficient to rebut the presumption that the payments, when recalculated, were applied properly under the contract’s provisions.
     Accordingly, the Court overruled the Debtors’ objection to U.S. Bank’s claim and allowed the claim as filed.