The coalition, which represents the interests of former customers, has consistently complained of high fees in the case.
Under the creditors' proposed plan, holders of about $1 billion in unsecured bonds would receive between 12 and 42 percent in recoveries. Lenders under a $1.2 billion revolver, led by JPMorgan Chase & Co, would recover between 27 and 80 percent of their claims. The group said in court papers those estimates are conservative.
The ad hoc group believes customers would be paid in full within three to six months, while other creditors would receive payouts within one year, according to a source close to the matter.
The outline of the plan is slated to go before Judge Martin Glenn on Feb. 14. If approved, the plan would go to creditors for a vote.
The group that proposed the plan owns about 65 percent of the roughly $2.2 billion in unsecured claims, so the plan already has widespread support.