Can I qualify for a cram down on the mortgage in a chapter 13 bankruptcy?

Interesting question. You are entitled to stip off any second mortgages that are "wholly unsecured", meaning that the value of the home is less than the amount owed on the first mortgage. The second mortgage would be treated as an unsecured loan. If the property was a multi-family, which you lived in and was also part investment, you are allowed to cram down the loan to the value of the property. The balance would be treated as an unsecured loan. If the property is your singe family home, the bankruptcy code does not provide for a cram down of a first mortgage. The question is can the loan/mortgage on the home that was initially for your own home, be transformed into an investment loan/property because you moved to California and no longer live in the home. Your argument would be that the property is no longer your residence and has become investment property and thus the loan is subject to a cram down. On the other hand, I would expect the lender to contend that the initial loan was taken out as a primary residence loan in which you declared your intent that you would reside in the home, and as a consequence the loan would not be subject to a cram down.