From the Editor – Dismissal

By The Honorable William Houston Brown (Retired)

Undistributed funds returned to debtor upon dismissal. Under § 1327(b)’s vesting requirement, unless a confirmed plan provides otherwise, any undistributed funds held by the trustee at dismissal of the case must be returned to the debtor. Although not necessary to rely on § 347(b)(3), the conclusion on effect of vesting at confirmation was consistent with that section and case law interpreting it. In re Hernandez, _________B.R._________, 2020 WL 773475 (Bankr. D. Conn. Jan. 17, 2020). See also In re Evans, _________B.R._________, 2020 WL . . .

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