Bankruptcy Professional Fees: Guidelines for Reviewing Fee Applications
(Fact Sheet, 03/06/95, GAO/GGD-95-36FS).

This fact sheet provides information on the guidelines used by Assistant
U.S. Trustees within the Justice Department to assess the reasonableness
of fee requests from attorneys and other professionals involved in
bankruptcy cases.  GAO surveyed Assistant U.S. Attorneys on (1) the
guidelines they used to review professionals' fee requests overall and
in chapter 11 cases specifically, (2) the reasons the local Office of
U.S. Trustees or other parties in bankruptcy cases have objected to
chapter 11 fee applications, and (3) the adequacy of compensation for
private trustees in chapter 7 cases.  GAO also examines differences in
the offices with and without guidelines in U.S. Trustee activities, such
as the time spent reviewing professional fee applications, the frequency
and the types of objectives made to those applications, and the
frequency of informal consultation on fee applications.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  GGD-95-36FS
     TITLE:  Bankruptcy Professional Fees: Guidelines for Reviewing Fee 
             Applications
      DATE:  03/06/95
   SUBJECT:  Bankruptcy
             Administrative costs
             Legal fees
             Compensation
             Lawyers
             Civil procedure
             Claims settlement
             Legal aid
             Trusts and estates law
             Surveys
IDENTIFIER:  DOJ U.S. Trustee Program
             
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Cover
================================================================ COVER


Fact Sheet for the Ranking Minority Member, Subcommittee on
Commercial and Administrative Law, Committee on the Judiciary, House
of Representatives

March 1995

BANKRUPTCY PROFESSIONAL FEES -
GUIDELINES FOR REVIEWING FEE
APPLICATIONS

GAO/GGD-95-36FS

Bankruptcy Professional Fees

(182006)


Abbreviations
=============================================================== ABBREV

  AUST - Assistant U.S.  Trustee
  OUST - Office of U.S.  Trustee

Letter
=============================================================== LETTER


B-259365

March 6, 1995

The Honorable John Conyers
Ranking Minority Member
Subcommittee on Commercial
 and Administrative Law
Committee on the Judiciary
House of Representatives

Dear Mr.  Conyers: 

This fact sheet responds to the request of the former Chairman of the
Subcommittee for information on the guidelines available to and used
by Assistant U.S.  Trustees (AUST) within the Department of Justice
to assess the reasonableness of fee requests from attorneys and other
professionals involved in bankruptcy cases.  It reflects responses
from 97 AUSTs, or their designees, to our survey soliciting
information on their experiences and views regarding (1) the
guidelines available to and used by AUSTs to review professionals'
fee requests overall and in chapter 11 cases specifically, (2) the
reasons the local Office of U.S.  Trustees (OUST) or other parties in
bankruptcy cases have objected to chapter 11 fee applications, and
(3) the adequacy of compensation for private trustees in chapter 7
cases.\1 As agreed with the Subcommittee, we also examined
differences in the offices with and without guidelines in U.S. 
Trustee activities such as (1) the time spent reviewing professional
fee applications, (2) the frequency and/or types of objections made
to those applications, and (3) the frequency of informal
consultations on fee applications. 


--------------------
\1 Private trustees usually are attorneys in private practice,
although some are accountants, real estate brokers, or other
professionals.  Private trustees are appointed by the U.S.  Trustees
to administer chapter 7, 12, and 13 bankruptcy cases.  Their exact
responsibilities vary, depending upon the chapter under which the
bankruptcy was filed.  For example, the responsibilities of chapter 7
trustees include collecting assets, converting them to cash, and,
upon court approval, distributing the proceeds to creditors and
professionals. 


   BACKGROUND
------------------------------------------------------------ Letter :1

The rapid rise in bankruptcy filings in the late 1980s generated
congressional concerns about the money paid to various professionals,
such as attorneys and accountants, hired to aid in the reorganization
or liquidation of bankrupt estates.  Congress was particularly
concerned about the size of fees charged by professionals in complex
and large chapter 11 business bankruptcies, where professional fees
could total millions of dollars although these total fees were a
small percentage of estate assets. 

Chapter 11 reorganization proceedings provide for the rehabilitation
of the business debtor.  The U.S.  Trustee's responsibilities in
chapter 11 cases include reviewing professionals' fee applications
and determining if the amounts requested are reasonable, given the
work performed.\2 In chapter 7 proceedings, which liquidate a
debtor's assets to pay creditors, the U.S.  Trustee is responsible
for overseeing the activities of private trustees who liquidate the
debtor's nonexempt assets to pay creditors.  The U.S.  Trustee
generally has little direct, detailed knowledge of most chapter 11
cases.  They receive 180-day reports in chapter 7 cases. 

In chapter 11 cases, the role of the U.S.  Trustee is substantially
more limited than that of other parties, such as the creditors
committees, debtors, and professionals.  The U.S.  Trustee does not
participate in the meetings between creditors committees and
professionals to determine goals and strategies of the parties, nor
is the U.S.  Trustee involved in many of the motions and other
proceedings.  The U.S.  Trustee may, from time-to-time or in specific
cases, confer with creditors and professionals about these matters,
but generally this occurs on an ad hoc basis.  Thus, the U.S. 
Trustee usually has little first-hand knowledge of the workings of
creditors and professionals and may not have the detailed knowledge
of a case to judge whether time charged or staffing are adequate,
appropriate, or even reasonable for the type of work performed. 
Moreover, professional fee applications, particularly in large and
complex bankruptcies, have generally been presented in a format that
showed billing entries in chronological order, making analysis and
review difficult. 

Because the amount of fees can be large and the issues related to the
reasonableness of the fees complex, many courts and U.S.  Trustee
offices have developed guidelines for professionals to use in
submitting their fee applications.  These guidelines were designed,
in part, to help U.S.  Trustees determine the reasonableness of
professional fee applications by assisting their review of whether
the time professionals charged for activities was accurately
reflected in their bills or whether the staffing of professionals was
excessive. 

To facilitate the U.S.  Trustees' review of professional fee
applications, many of the written U.S.  Trustee guidelines prescribed
format and billing requirements.  In addition, some court guidelines
have required that other professionals, designated by the fee
applicant, certify that fee applications comply with any local court
guidelines and that fees and disbursements are billed at rates in
accordance with those usually charged by the applicant and generally
accepted by the applicant's clients.  Finally, the guidelines also
were designed to give professionals examples of the types of
objections that the U.S.  Trustee may raise to fee applications. 

U.S.  Trustees may have formal written guidance and/or informal
guidance for reviewing fee applications.  If reasons exist to
question all or a portion of a fee application, the U.S.  Trustee may
file a fee objection with the bankruptcy court seeking a reduction in
the fee.  However, the bankruptcy judge has final approval of
professional fee applications. 


--------------------
\2 For cases filed under other chapters of the bankruptcy code, the
U.S.  Trustee's responsibilities include appointing private trustees
(who are usually attorneys in private practice) to administer the
cases.  A brief description of the major bankruptcy chapters and the
U.S.  Trustee Program is found in app.  I. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :2

All 97 AUSTs surveyed, or their designees, returned the
questionnaire, although some respondents did not answer every
question.  About one-third (31) of AUSTs said they had written U.S. 
Trustee guidelines, about one-half (50) had written court directives
regarding professional fees (17 had both), and about two-thirds (65)
had unwritten guidelines governing professional fee applications. 

Of the AUSTs with written guidelines, about one-third (10 of 31) with
Trustee guidelines and one-half (26 of 50) with judicial directives
indicated they had guidelines specific to chapter 11 cases.  About
two-fifths (26 of 65) of the AUSTs with unwritten court/judicial
guidelines had guidelines applicable to chapter 11 cases.\3

The written guidelines or directives used most often by AUSTs in
chapter 11 bankruptcy cases addressed the specific format for the
submission of professional fee applications and the lodestar
formula.\4 The two unwritten guidelines used most often were those
related to holdbacks\5 and the lodestar formula. 

The most common reasons OUSTs objected to chapter 11 fee applications
were insufficient description of the work performed and "lumping," or
failing to list separately each task and the time required to
complete them.  The OUSTs objected most frequently to applications
from attorneys for the debtor and least frequently to over-secured
creditors and realtors. 

OUSTs with all three forms of guidelines--trustee and court written
guidelines plus unwritten guidelines--objected to chapter 11 fee
applications more frequently, held informal consultations prior to
fee hearings less frequently, and devoted a greater percentage of
staff time to reviewing fee applications than those offices with no
guidelines. 

The majority of AUSTs (85) reported that bankruptcy judges awarded
private trustees in chapter 7 cases the statutory maximum
compensation permitted at least 81 percent of the time; and 27
reported judges awarded the maximum compensation 100 percent of the
time.  The majority of AUSTs (89) believed private trustee
compensation should be increased.\6 AUSTs reported that excessive
paperwork was more important than insufficient compensation as a
reason private trustees voluntarily left their positions, while
challenging work and a dependable source of income were the most
important reasons private trustees remained in their positions. 


--------------------
\3 We defined unwritten or informal guidelines as those known to be
used by judges or the courts but which are not formally recorded or
published as guidelines.  According to one AUST the unwritten
guidelines or rules are generally based on case law.  For example,
one court had an informal rule forbidding approval of chapter 7 fee
applications in which administrative expenses exceeded one-third of
total distributions from the dissolution of the estate. 

\4 The lodestar formula is used to establish a standard for assessing
the reasonableness of professional fees.  The formula is based on the
number of hours the professional expended multiplied by a reasonable
hourly rate.  The formula is not designed to assess the
reasonableness of the hours expended. 

\5 Holdbacks refer to the practice whereby only a portion of the
requested professional fees are allowed on an interim basis.  The
remainder of the requested interim fees would be allowed, if at all,
at the conclusion of the representation along with the professional's
final fee application. 

\6 The Bankruptcy Reform Act of 1994 (P.L.  103-394) contains several
provisions that provide for increased trustee compensation. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
------------------------------------------------------------ Letter :3

Our objectives were to obtain information on the (1) types of formal
and informal guidelines available to and used by U.S.  Trustees to
review professional fee applications, (2) the type of objections made
to professional fee applications, and (3) the adequacy of
compensation to private trustees appointed to administer chapter 7
cases.  We mailed questionnaires to survey 97 AUSTs or their
designees in the 92 U.S.  Trustee field offices between May and July
1993\7 .  We received responses from all 97 of those surveyed.\8
However, some respondents did not answer every question on the
questionnaire.  We surveyed the AUSTs because they are responsible
for overseeing the private trustees --about 2,000 for chapter 7 cases
alone--who are directly responsible for the orderly administration of
bankrupt estates.  We asked the AUSTs for their experiences and views
regarding professional fees in bankruptcy cases. 

We reviewed the survey responses for any relationships between the
number of guidelines applicable to chapter 11 (U.S.  Trustee
guidelines, judicial district directives, and judges/courts unwritten
guidelines or rules) and other factors, such as the frequency of
objections, frequency of informal consultations before fee hearings,
and the amount of staff's time spent reviewing applications.  We also
reviewed the questionnaire results for differences in such factors as
the frequency of objections and informal consultations between
offices with all three forms of guidance and those with no guidance. 
We did not obtain agency comments because the results of the survey
reflect the personal responses of those surveyed, and the fact sheet
does not include conclusions or recommendations. 

The survey questions are shown in appendix II.  Appendix III provides
more detailed data on the types of guidelines available to U.S. 
Trustees, including the bankruptcy chapters to which those guidelines
apply.  Appendix IV provides data on the use of the guidelines in
reviewing professional fee applications in chapter 11 cases. 
Appendix V includes responses on chapter 7 questions, including the
compensation and retention of private trustees. 

We are sending copies of this fact sheet to the Chairmen of the House
and Senate Judiciary Committees; the Ranking Minority Member of the
Senate Judiciary Committee; the Attorney General; the Executive
Director of the Executive Office for U.S.  Trustees; the Director,
Office of Management and Budget; and other interested parties.  We
will also make copies available to others upon request. 

Please contact me on (202) 512-8777 if you have questions concerning
this fact sheet.  The major contributors to this fact sheet are
listed in appendix VI. 

Sincerely yours,

Laurie E.  Ekstrand
Associate Director, Administration
 of Justice Issues


--------------------
\7 Given our limited resources, We postponed formally reporting the
results of the survey while we completed a report for the
subcommittee on professional fees in chapter 7 cases. 

\8 For nine offices in which the AUST position was either vacant or
not designated, the questionnaire was completed by the
attorney-in-charge.  For two offices, the questionnaire was completed
by the U.S.  Trustee in whose region the office was located.  Both
the AUST and attorney-in charge responded for one office.  Three
field offices had more than one AUST. 


THE U.S.  TRUSTEE PROGRAM
=========================================================== Appendix I

In 1978, Congress passed the Bankruptcy Reform Act (P.L.  95-598),
which established the U.S.  Trustee Program as a pilot effort in 18
federal judicial districts.  The act thereby shifted administrative
and supervisory responsibilities for bankruptcy cases in these 18
districts from the courts to the Department of Justice.  The
legislation also prescribed maximum compensation levels for the
services rendered by private trustees and other professionals in
bankruptcy cases.  In 1986, Public Law 99-554\1

expanded the program to all 94 judicial districts\2 and established
21 regions, each administered by a U.S.  Trustee appointed by the
Attorney General.  This law also provides for a self-funding
mechanism whereby the program receives, for example, a portion of the
fees assessed against those who file bankruptcy cases. 

Currently, the program operates 92 U.S.  Trustee field offices that
oversee the administration of bankruptcy cases filed in the 88
judicial districts.  Field offices are typically staffed by one or
more Assistant U.S.  Trustees (AUST), attorneys, bankruptcy analysts,
paralegals, case management specialists, legal clerks, legal data
technicians, and administrative support staff.  While the field
offices can directly administer bankruptcy cases, they more commonly
oversee the administration of cases by private trustees in chapter 7,
12, and 13 cases--about 2,000 private trustees for chapter 7 cases
alone.  The U.S.  Trustee field offices supervise the administration
of cases filed under four of the five types of bankruptcy proceedings
defined under the Bankruptcy Code: 

  -- proceedings under chapter 7 in which the assets of the debtor
     are liquidated;

  -- reorganization proceedings under chapter 11 for rehabilitation
     of the business debtor;

  -- reorganization proceedings under chapter 12 for the adjustment
     of debts of a family farmer; and

  -- adjustment of debts of an individual with regular income under
     chapter 13, pursuant to which an individual can adopt a plan to
     discharge certain debts after making payments over a period of
     time, usually not to exceed 36 months. 

U.S.  Trustees have little role in proceedings under chapter 9, which
relates to the adjustment of debts of a municipality. 

The U.S.  Trustees' specific responsibilities include (1) monitoring
applications to employ professionals, (2) appointing private
trustees, (3) reviewing the fee applications of professionals, and
(4) filing objections with bankruptcy judges to fee applications that
the U.S.  Trustee considers inappropriate and improper. 


--------------------
\1 The Bankruptcy Judges, United States Trustees, and Family Farmer
Bankruptcy Act of 1986. 

\2 Congress authorized six bankruptcy districts in the states of
North Carolina and Alabama to delay their entry into the U.S. 
Trustee Program until 1992, subsequently extending the date 10 years
to 2002.  In these six districts, a separate, parallel program with
objectives identical to those of the U.S.  Trustee Program was
created and operates within the judicial branch.  Thus, there are
currently 88 districts participating in the U.S.  Trustee Program. 
See Bankruptcy Administration:  Justification Lacking for Continuing
Two Parallel Programs (GGD-92-133, Sept.  28, 1992). 


SURVEY OF U.S.  TRUSTEES
========================================================== Appendix II

Survey Questions
----------------------------------------------------------------------
1. In which judicial district(s) does your office have responsibility?

2. How many years have you held the Assistant U.S. Trustee position?

3. For your region, are there published U.S. Trustee guidelines on
professional fees in bankruptcy cases?

No

Yes

4. When did the published U.S. Trustee guidelines go into effect?

5. For which chapter(s) do these guidelines apply?

Chapter 7

Chapter 11

Chapter 12

Chapter 13

Published guidelines apply to no particular chapter

6. Has your district developed and published directives on
professional fees in bankruptcy cases?

No

Yes

7. Which of the following forms do the published directives in your
district take?

Formal orders

Local rules

Official forms

Other


8. When did your district's directives go into effect?

9. For which chapter(s), if any, do these directives apply?

Chapter 7

Chapter 11

Chapter 12

Chapter 13

Published directives apply to no particular chapter

10. Are there judge/court-specific unwritten guidelines or rules on
professional fees in bankruptcy cases?

No

Yes

11. For which of the following chapter(s) do these unwritten
guidelines apply?

Chapter 7

Chapter 11

Chapter 12

Chapter 13

Guidelines apply to no particular chapter

12. Regarding professional fees in bankruptcy cases, which of the
following have been used in the past year in your district in Chapter
11 cases by the court and the Office of U.S. Trustee?

Ad hoc committees

Fee analyst (outside entity used to examine fees)

Statements of expected services and costs in advance (up-front
budgets)

Limiting the number of committees

Limiting the size of committees

Mediation

Specific format for the submission of fee applications

Caps on hourly rates

OUST written response required on fee applications

Court hearing and appearance required on fee applications

Lodestar formula

Holdbacks

Restrictions on locations/participants in committee meetings

Sharing of professionals

Other


13. Is there anything about the court's use of unwritten guidelines/
rules that you would like to comment on or give additional information
about?

14. In your experience, in the past year, did anyone file an objection
to fee applications in Chapter 11 or Chapter 7 cases?

No

Yes

15. In the past year, about what percentage of your staff's time was
spent reviewing Chapter 11 fee applications?

16. Currently, for Chapter 11 fee applications, how often, if at all,
does informal consultation occur between your office and professionals
before fee hearings?

All of the time

81% to 99% of the time

61% to 80% of the time

41% to 60% of the time

21% to 40% of the time

1% to 20% of the time

None of the time

Not sure

No basis to judge

17. In the past year, in what percentage, if any, of Chapter 11 fee
applications did your office file an objection?

All of the applications

81% to 99% of the applications

61% to 80% of the applications

41% to 60% of the applications

21% to 40% of the applications

1% go 20% of the applications

None of the applications

Not sure

18. Consider Chapter 11 fee applications in which your office formally
objected. How often, if at all, in the past year, did your office
formally object for the following reasons?

Lack of showing benefit to the estate

Total amount of fees in relation to total value of estate

Duplication of services/efforts

Excessive hours worked

Excessive hourly rates for the services performed

Excessive hourly rates for the persons performing those services

Charges for fee application preparation

Full hourly rates for travel time

Excessive lodging and travel expenses

Charges for amenities while in travel status, etc.

Charging in excess of the tax deductible amount in mileage

Parking fees while appearing in court

Not complying with formatting requirements for fee applications or
requests for reimbursement of expenses

Not keeping time in appropriate increments

Insufficient description of the work done

Not listing separately each task and the time required for that task
("lumping")

Inadequate documentation of expenses for which reimbursement is
sought

Use of professionals to perform tasks which a paraprofessional could
perform

Computerized research charges in excess of actual costs as billed to
the professional

19. Consider Chapter 11 fee applications in which your office filed an
objection. How often, if at all, in the past year, did your office
make objections to the following professionals?

Attorney for debtor

Attorney for creditor

Attorney for creditors' committee

Investment banker/financial advisor

Accountants

Realtors

Attorney for equity holders' committee

Over-secured creditors

Other

20. In the past year, in Chapter 11 fee applications in which other
parties filed an objection, how often, if at all, did each of the
following parties object?

Trustee

Debtor

Creditor

Creditors' committee

Judge/court

Attorney for equity holders' committee

Other

21. For each party objecting in Question 20, please describe briefly
the reason(s) for objecting.

22. In the past year, about what percentage of staff time was spent
reviewing Chapter 7 fee applications?

23. Currently, for Chapter 7 fee applications, how often does informal
consultation occur between your office and professionals before fee
hearings?

All of the time

81% to 99% of the time

61% to 80% of the time

41% to 60% of the time

21% to 40% of the time

1% to 20% of the time

None of the time

Not sure

No basis to judge

24. In the past year, in what percentage of Chapter 7 fee
applications, if any, did your office formally object?

25. In the past year, of the private trustees in your district who are
attorneys, approximately what percentage of them retain themselves or
their law firm as attorney(s) for trustee?

26. In the past year, in approximately what percentage of bankruptcy
cases do the private trustees retain themselves or their law firm as
attorney(s) for trustee?

27. In the past year, in what percentage of bankruptcy cases do judges
in your district routinely award, as compensation to private trustees,
the statutory maximum on fees?

All of the cases

81% to 99% of the cases

61% to 80% of the cases

41% to 60% of the cases

21% to 40% of the cases

1% to 20% of the cases

None of the cases

Not sure

No basis to judge

28. In the past year, what problems, if any, did your district
experience in the Chapter 11 fee application process with the
following types of professionals?

Accountants

Attorneys

Investment bankers/financial advisors

Management companies

Other

29. If your district encountered problems in the past year with any of
the professionals listed in Question 28 in connection with the Chapter
11 bankruptcy fee application process, briefly describe the
problem(s).

30. What do you view as the greatest problem(s) in the bankruptcy fee
application process?

31. What would your proposal be to reduce or control professional fees
in bankruptcy cases?

32. Consider all the work of your office. In your opinion, how much
priority, if any, would you give each of the following activities?

Administrative matters (e.g., quarterly fees, 180-day reports, etc.)

Monitoring private trustees

Investigating fraud and misconduct allegations

Analyzing Chapter 11 disclosure statements

Reviewing Chapter 11 fee applications

Responding to public inquiries

Other

33. Excluding those private trustees who left because they were
removed, about how many private trustees voluntarily left their
positions in the past two years?

34. Which of the following, if any, were important reasons for those
private trustees who have voluntarily left their positions?

Requirements by the Executive Office for U.S. Trustees

The caseload was too heavy

Income after expenses was too low

Too much paperwork involved in being a trustee

Trustees were not paid in a timely manner

Retired

Other

35. For those private trustees who have remained in their positions,
how important were the following reasons?

Self-marketing opportunities

Prestige

Interesting/challenging work

Financial rewards

Dependable income for law practice or other professional endeavor

Investment in time and equipment

Other

36. In your opinion, should private trustee compensation be increased,
decreased, or remain about the same?

Greatly increased

Somewhat increased

Remain about the same

Somewhat decreased

Greatly decreased

No opinion
----------------------------------------------------------------------

ASSISTANT U.S.  TRUSTEES'
RESPONSES REGARDING GUIDELINES
AVAILABLE TO ASSESS PROFESSIONAL
FEES IN BANKRUPTCY CASES
========================================================= Appendix III

Of the 97 Assistant U.S.  Trustees (AUST), or their designees, who
responded to our survey on guidelines for professional fees in
bankruptcy cases, about one-third reported having written U.S. 
Trustee guidelines, about one-half had written judicial directives,
and about two-thirds had unwritten judge rules or directives (see
table III.1).  The majority of the 31 AUSTs who reported having
written U.S.  Trustee guidelines on fees reported having the other
two forms of guidance as well--written judicial directives and
unwritten judge/court rules or directives.  About 52 percent of these
31 AUSTs indicated that their own written guidelines specifically
applied to at least one of four chapters (chs.  7, 11, 12 and 13)
under which bankruptcies are filed, as shown in figure III.1. 

Of the remaining 66 AUSTs without written U.S.  Trustee guidelines on
professional fees, all but 8 (12 percent) had guidance in the form of
judicial district directives or judges/courts unwritten guidelines or
rules (see fig.  III.2).  About one-third (10 of 31) of those with
written U.S.  Trustee guidelines, one-half (26 of 49) of those with
written judicial district directives, and two-fifths (26 of 65) of
those with unwritten guidelines/rules had guidelines specifically
applicable to chapter 11 cases (see fig.  III.3). 

Table III.2 lists the types of guidelines that were available within
each district where the 97 AUSTs have offices.  As the table
indicates, more than one type of guideline may have been available in
each AUST office.  Table III.3 summarizes the different mixes of
guidelines that were available to AUSTs at the time of our survey. 
Tables III.4 through III.7 provide additional information on specific
types of guidelines that were available and the bankruptcy chapters
to which they applied. 



                              Table III.1
                
                 The Number of Assistant U.S. Trustees
                    Who Reported Having Some Type of
                 Guidelines on Fees in Bankruptcy Cases

                                                                Percen
Type of guideline                                       Number       t
------------------------------------------------------  ------  ------
Published U.S. Trustee guidelines                         31\a     32%
Judicial district directives                                50      52
Judges/court unwritten rules                                65      67
----------------------------------------------------------------------
Note:  All 97 AUSTs responded to this question. 

\a Twenty-five respondents reported that guidelines took effect
between May 1988 and July 1993. 

   Figure III.1:  Percentage of
   Written U.S.  Trustee
   Guidelines on Professional Fees
   That Applied to One or More
   Bankruptcy Chapters or Applied
   to No Specific Chapter

   (See figure in printed
   edition.)

Note 1:  Percentages are based on the 31 AUSTs who reported having
written, published U.S.  Trustee guidelines on professional fees in
bankruptcy cases. 

Note 2:  One respondent checked four bankruptcy chapters in addition
to no particular chapter on the questionnaire.  This respondent was
included in the category of two to four chapters. 

Note 3:  Numbers do not add to 100 due to rounding. 

   Figure III.2:  Type of Guidance
   Available to 66 Assistant U.S. 
   Trustees Without Written U.S. 
   Trustee Guidelines on
   Professional Fees in Bankruptcy
   Cases

   (See figure in printed
   edition.)

   Figure III.3:  Types of
   Guidance Available to Assistant
   U.S.  Trustees Regarding
   Professional Fees in Bankruptcy
   Cases (Guidance Applicable to
   Chapter 11 Cases Shown
   Separately)

   (See figure in printed
   edition.)

Note 1:  Numbers are based on the responses of all 97 AUSTs surveyed. 

Note 2:  An AUST may have more than one type of guideline available,
as shown in table III.2. 

Note 3:  Guidelines applicable to chapter 11 may apply to other
chapters as well. 



                              Table III.2
                
                    Guidelines on Professional Fees
                  Available Within the Districts Where
                  Assistant U.S. Trustees Have Offices

                                                              Unwritte
                                  Published      Published    n
Judicial district Office of U.S.  U.S. Trustee   court        guidelin
Trustee covers                    guidelines     directives   es
--------------------------------  -------------  -----------  --------
Alaska                                           X            X

Arizona                                                       X

Arkansas, Eastern                 X                           X

California, Central               X              X            X

California, Central               X              X            X

California, Central               X              X            X

California, Central               X              X            X

California, Central               X              X            X

California, Eastern                              X

California, Eastern                              X            X

California, Northern              X              X

California, Northern              X              X

California, Northern                             X

California, Southern              X              X            X

California, Southern              X              X            X

Colorado                          X              X            X

Connecticut                                      X            X

Florida, Middle                   X

Florida, Middle                   X              X

Florida, Northern                                             X

Florida, Northern                                             X

Georgia, Middle

Georgia, Northern                                X            X

Georgia, Southern

Guam                              X

Hawaii                                                        X

Idaho                                                         X

Illinois, Central                 X              X

Illinois, Northern                                            X

Illinois, Northern                                            X

Indiana, Northern                 X

Indiana, Southern                 X

Iowa, Northern                    X              X

Iowa, Southern                    X

Kansas                            X                           X

Kentucky, Western                                             X

Kentucky, Western                                             X

Louisiana, Eastern                                            X

Louisiana, Western                               X            X

Maine                                            X            X

Maryland                                                      X

Maryland                          X                           X

Massachusetts                                                 X

Massachusetts                                    X            X

Michigan, Eastern                                X

Michigan, Western                                X            X

Minnesota                         X              X

Mississippi, Northern                                         X

Missouri, Eastern                                X

Missouri, Western                 X                           X

Montana                                                       X

Nebraska                                                      X

Nevada                            X                           X

Nevada

New Hampshire                                    X            X

New Jersey                                       X            X

New Mexico

New York, Eastern

New York, Northern                               X

New York, Northern                               X

New York, Southern                               X

New York, Western                                             X

New York, Western

Ohio, Northern                                   X

Ohio, Southern                                   X            X

Ohio, Southern                                   X            X

Oklahoma, Northern                X              X            X

Oklahoma, Western

Oregon                                           X

Oregon                                           X

Pennsylvania, Eastern                                         X

Pennsylvania, Middle                             X            X

Pennsylvania, Western                            X

Puerto Rico                                                   X

South Carolina                    X

South Dakota                      X

Tennessee, Eastern                                            X

Tennessee, Middle

Tennessee, Western                X                           X

Texas, Eastern                                                X

Texas, Northern                                               X

Texas, Southern                                  X            X

Texas, Southern                                  X            X

Texas, Western                                   X            X

Texas, Western                                   X            X

Texas, Western                                   X            X

Utah                                                          X

Virginia, Eastern                 X              X            X

Virginia, Eastern                                             X

Virginia, Eastern                 X                           X

Virginia, Western                 X              X            X

Washington, Eastern                              X            X

Washington, Western                              X            X

Wisconsin, Eastern                                            X

Wisconsin, Western                                            X

West Virginia, Northern                          X            X

Wyoming                                          X            X
----------------------------------------------------------------------
Note:  Some judicial districts have more than one AUSTs. 



                              Table III.3
                
                   Number of Assistant U.S. Trustees
                    Reporting Different Types of Fee
                               Guidelines

Type of guideline                                               Number
--------------------------------------------------------------  ------
Judicial district directives only                                   11
Judge/court unwritten rules only                                    25
U.S. Trustee guidelines and judicial district directives             6
U.S. Trustee guidelines and judge/court                              7
 unwritten rules
U.S. Trustee guidelines, judicial district directives and           11
 judge/court unwritten rules
Judicial district directives and judge/court unwritten rules        22
No guidelines                                                        8
======================================================================
Total                                                               97
----------------------------------------------------------------------


                              Table III.4
                
                 The Percentage of Written U.S. Trustee
                  Fee Guidelines That Applied to Each
                           Bankruptcy Chapter

                                                                Percen
Chapter                                                              t
--------------------------------------------------------------  ------
No particular chapter                                              52%
Chapter 7                                                           39
Chapter 11                                                          32
Chapter 12                                                          13
Chapter 13                                                          16
----------------------------------------------------------------------
Note 1:  Percentages based on the 31 AUSTs who reported having
written U.S.  Trustee guidelines on bankruptcy professional fees. 

Note 2:  Guidelines may apply to more than one bankruptcy chapter. 

Note 3:  One respondent checked all the boxes--one for each chapter
plus one for no particular chapter. 



                              Table III.5
                
                 Type of Form in Which Written Judicial
                     District Directives on Fees in
                    Bankruptcy Cases Were Published

                                                                Percen
Form directive takes                                                 t
--------------------------------------------------------------  ------
Local rules                                                        80%
Formal orders                                                       18
Official forms                                                      12
Other                                                               16
----------------------------------------------------------------------
Note:  Percentages based on the 50 AUSTs who reported having written
judicial directives on bankruptcy professional fees. 



                              Table III.6
                
                   The Percentage of Written Judicial
                District Directives on Fees That Applied
                       to Each Bankruptcy Chapter

                                                                Percen
Chapter                                                              t
--------------------------------------------------------------  ------
No particular chapter                                               47
Chapter 7                                                           51
Chapter 11                                                         53%
Chapter 12                                                          45
Chapter 13                                                          41
----------------------------------------------------------------------
Note:  Percentages based on the 49 AUSTs who reported having written
judicial directives on bankruptcy professional fees. 



                              Table III.7
                
                  The Percentage of Unwritten Rules on
                  Fees That Applied to Each Bankruptcy
                                Chapter

                                                                Percen
Chapter                                                              t
--------------------------------------------------------------  ------
No particular chapter                                              55%
Chapter 7                                                           34
Chapter 11                                                          40
Chapter 12                                                          14
Chapter 13                                                          37
----------------------------------------------------------------------
Note:  Percentages based on the 65 AUSTs who reported having
unwritten rules or guidelines on bankruptcy professional fees. 


ASSISTANT U.S.  TRUSTEES'
RESPONSES REGARDING THE REVIEW OF
PROFESSIONAL FEE APPLICATIONS IN
CHAPTER 11 CASES, INCLUDING THE
USE OF AVAILABLE GUIDELINES
========================================================== Appendix IV

This appendix provides, for chapter 11 cases, information on the
formal and informal guidelines used, the frequency of informal
consultations prior to formal fee hearings, the frequency of
objections to professional fee applications, the reasons U.S. 
Trustees and other parties objected to fee applications, the
categories of professionals most and least frequently objected to,
and the activities to which U.S.  Trustees gave highest priority. 


   OVERVIEW
-------------------------------------------------------- Appendix IV:1

Tables IV.1 and IV.2 show which formal and informal guidelines were
used by the courts, the U.S.  Trustee, or both.  About 90 percent of
the Assistant U.S.  Trustees (AUST) reported that no more than
one-fifth of their staff time was spent reviewing applications; about
60 percent said no more than 10 percent of staff time was expended on
this task. 

About 60 percent of the AUSTs reported that more than three-fifths of
the time the Office of U.S.  Trustee (OUST) and professionals held
informal consultations on chapter 11 fee applications prior to formal
fee hearings (table IV.3).  Just over 70 percent of AUSTs reported
filing formal objections to professional fees in no more than 40
percent of the chapter 11 fee applications (table IV.4).  The two
most frequent reasons for objecting were insufficient description of
the work done and "lumping," or failing to list separately each task
and the time required to complete it (table IV.5).  The category of
professional most frequently objected to was attorney for the
debtors.  Over-secured creditors and realtors were the categories to
whom AUSTs least frequently objected.  (See tables IV.6 and IV.7.)

Among other parties in bankruptcy cases, judges and creditors
objected most frequently to chapter 11 fees (table IV.8) and debtors
least frequently (table IV.9).  The reasons other parties gave for
objecting to chapter 11 fee applications are shown in tables IV.10
(top 5 reasons) and IV.11 (detailed breakdown). 

AUSTs reported experiencing the most problems with investment
bankers/financial advisors and accountants (table IV.12) and the
fewest problems with management companies and attorneys (table
IV.13).  AUSTs reported giving highest priority to monitoring private
trustees, investigating fraud and misconduct allegations, and
completing administrative tasks (table IV.14). 



                                    Table IV.1
                     
                      Type of Written Guidelines/Directives
                     Used Within the Past Year in Chapter 11
                                      Cases


                                                   Court
                                                     and             Not
Written guidelines        Court only   OUST only    OUST   Total    used   Total
------------------------  ----------  ----------  ------  ------  ------  ------
Specific format for the           30           7      15      52      25      77
 submission of fee
 applications
Lodestar formula                  15           2      21      38      30      68
Court hearing and                              0      13      26      46      72
 appearance
 required on fee
 applications
Limiting the size of               0          13       3      16      56      72
 committees
Holdbacks                          5           2       8      15      42      57
Limiting the number of             0           8       5      13      60      73
 committees
Ad hoc committees                  2           6       4      12      67      79
OUST written response              2           4       5      11      63      74
 required on fee
 applications
Statements of expected             4           2       4      10      66      76
 services and costs in
 advance (up-front
 budgets)
Sharing of professionals           0           0       9       9      59      68
Caps on hourly rates               7           0       1       8      61      69
Fee analyst (outside               6           0       2       8      71      79
 entity used to examine
 fees)
Mediation                          5           1       0       6      70      76
Restrictions on                    1           1       2       4      71      75
 locations/participants
 in committee meetings
--------------------------------------------------------------------------------
Note:  Totals do not add to 97 because some AUSTs did not respond to
some questions. 



                                    Table IV.2
                     
                     Type of Unwritten Guidelines/Rules Used
                     Within the Past Year in Chapter 11 Cases


                                                   Court
                                                     and             Not
Unwritten guidelines      Court only   OUST only    OUST   Total    used   Total
------------------------  ----------  ----------  ------  ------  ------  ------
Holdbacks                         26           4      44      74      14      88
Lodestar formula                  15           4      46      65      15      80
Limiting the number of             1          33      10      44      37      81
 committees
Caps on hourly rates              25           1      15      41      41      82
Limiting the size of               0          37       1      38      39      77
 committees
Court hearing and                 16           4      17      37      41      78
 appearance required on
 fee applications
Specific format for the           14           2      21      37      29      66
 submission of fee
 applications
Sharing of professionals           9           2      13      24      53      77
Statements of expected             7           6       9      22      55      77
 services and costs in
 advance (up-front
 budgets)
Mediation                         10           4       1      15      63      78
OUST written response              1           6       7      14      68      82
 required on fee
 applications
Fee analyst (outside               7           0       2       9      71      80
 entity used to examine
 fees)
Restrictions on                    4           3       1       8      70      78
 locations/participants
 in committee meetings
Ad hoc committees                  3           1       1       5      72      77
--------------------------------------------------------------------------------
Note:  Totals do not add to 97 because some AUSTs did not respond to
some questions. 



                               Table IV.3
                
                      Percentage of Time Informal
                Consultations Occurred Before Chapter 11
                              Fee Hearings

                                                             Number of
Percent of time                                                  AUSTs
------------------------------------------------------  --------------
1% to 20%                                                           13
21 to 40                                                            15
41 to 60                                                            13
61 to 80                                                            20
81 to 99                                                            28
100                                                                  8
----------------------------------------------------------------------
Note:  All 97 AUSTS surveyed responded to this question. 



                               Table IV.4
                
                    The Percentage of Chapter 11 Fee
                Applications To Which the Office of U.S.
                 Trustees Filed an Objection Within the
                               Past Year

                                                             Number of
Percent of applications                                          AUSTs
------------------------------------------------------  --------------
None                                                                 1
1% to 20%                                                           41
21 to 40                                                            27
41 to 60                                                            11
61 to 80                                                            10
81 to 99                                                             5
100                                                                  1
----------------------------------------------------------------------
Note 1:  A total of 96 AUSTs responded to this question. 

Note 2:  Assistant U.S.  Trustees reported on average that 13 percent
of staff's time was spent reviewing applications. 



                                    Table IV.5
                     
                       Reasons the Office of U.S. Trustees
                       Formally Objected to Chapter 11 Fee
                                   Applications


                             Most of  About half     Some of   Seldom or
Reasons for objection       the time    the time    the time       never   Total
------------------------  ----------  ----------  ----------  ----------  ------
Insufficient description          55          15          18           8      96
 of the work done
Not listing separately            47          15          21          13      96
 each task and the time
 required for that task
 ("lumping")
Not keeping time in               30           8          28          30      96
 appropriate increments
Not complying with                29          16          17          26      88
 formatting requirements
 for fee applications or
 requests for
 reimbursement of
 expenses
Overhead or any of the            26          14          28          28      96
 normally accepted
 components of overhead
Inadequate documentation          25          22          26          24      97
 of expenses for which
 reimbursement is sought
Lack of showing benefit           21          15          30          31      97
 to the estate
Duplication of services/          17          20          40          19      96
 efforts
Fax charges for sending           15           9          21          51      96
 or receiving a fax
 other than telephone
 toll charges
Full hourly rates for             15          17          27          36      95
 travel time
Word processing charges           14          10          20          50      94
Use of professionals to           14          16          27          40      97
 perform tasks which a
 paraprofessional could
 perform
Total amount of fees in           12           9          24          51      96
 relation to total value
 of estate
Charges for amenities             10           2          13          68      93
 while on travel status,
 etc.
Unnecessary use of                10           2          19          66      97
 overnight delivery or
 messenger services
Staff overtime                    10           4          24          56      94
Excessive hours worked             9          10          42          36      97
Local meals for                    9           4          11          67      91
 professionals or staff
 required to work during
 lunch or after hours
Excessive hourly rates             8           8          23          57      96
 for the persons
 performing those
 services
Excessive lodging and              7           0          21          67      95
 travel expenses
Excessive hourly rates             7          10          28          51      96
 for the services
 performed
Computerized research              7           1           9          78      95
 charges in excess of
 actual cost as billed
 to the professional
Charges for fee                    6           9          15          64      94
 application preparation
Reimbursement of                   4           1           5          86      96
 creditors' committee
 out-of-pocket expenses
Parking fees while                 4           0           3          83      90
 appearing in court
Charging in excess of              4           0           7          79      90
 the tax deductible
 amount in mileage
--------------------------------------------------------------------------------
Note:  Some totals do not add to 97 because some AUSTs either checked
"do not apply" or did not respond. 



                               Table IV.6
                
                   Professionals Who Were Most Often
                    Objected to in Chapter 11 Cases

                                                        Number  Percen
                                                            of    t of
Professional                                             AUSTs   AUSTs
------------------------------------------------------  ------  ------
Attorney for debtor\a                                       65     68%
Accountants\b                                               38      40
----------------------------------------------------------------------
Note 1:  Responses reflected those professionals who AUSTs said were
objected to at least half the time. 

Note 2:  The total number of responses varied as follows: 

\a A total of 95 AUSTs responded to this question. 

\b A total of 96 AUSTs responded to this question. 



                               Table IV.7
                
                   Professionals Who Were Least Often
                    Objected to in Chapter 11 Cases

                                                        Number  Percen
                                                            of    t of
Professional                                             AUSTs   AUSTs
------------------------------------------------------  ------  ------
Over-secured creditors\a                                    71     78%
Realtors\b                                                  73      77
Attorney for creditor\c                                     70      73
Attorney for equity holders' committee\b                    52      55
----------------------------------------------------------------------
Note 1:  Responses reflect those professionals to whom AUSTs said
they seldom or never objected. 

Note 2:  The total number of responses to each question varied as
follows: 

\a A total of 91 AUSTs responded to this question. 

\b A total of 95 AUSTs responded to this question. 

\c A total of 96 AUSTs responded to this question. 



                               Table IV.8
                
                Other Parties Who Objected Most Often to
                            Chapter 11 Fees

                                                        Number  Percen
                                                            of    t of
Party                                                    AUSTs   AUSTs
------------------------------------------------------  ------  ------
Creditor                                                    27     28%
Judge/court                                                 24      25
----------------------------------------------------------------------
Note 1:  Responses reflect other parties who AUSTs said objected at
least half the time. 

Note 2:  A total of 95 AUSTs responded to this question. 



                               Table IV.9
                
                 Other Parties Who Objected Least Often
                           to Chapter 11 Fees

                                                        Number  Percen
                                                            of    t of
Party                                                    AUSTs   AUSTs
------------------------------------------------------  ------  ------
Debtor\a                                                    72     76%
Private trustee\a                                           66      69
Attorney for equity holders' committee\b                    51      54
----------------------------------------------------------------------
Note 1:  Responses reflected other parties who AUSTs said seldom or
never objected. 

Note 2:  The total number of responses varied as follows: 

\a A total of 95 AUSTs responded to this question. 

\b A total of 94 AUSTs responded to this question. 



                              Table IV.10
                
                The Top Five Reasons Other Parties Gave
                    for Objecting to Chapter 11 Fee
                              Applications

Reasons for objections
----------------------------------------------------------------------
Lack of showing benefit to the estate

Total amount of fees in relation to total value of estate

Duplication of services/efforts

Insufficient description of the work done

Excessive hours worked
----------------------------------------------------------------------
Note:  Respondents were given a choice of 26 reasons for objections
from which to select.  See table IV.11 for a more detailed breakdown. 



                                   Table IV.11
                     
                     Reasons Other Parties Gave for Objecting
                          to Chapter 11 Fee Applications


                                                                        Attorney
                                                                             for
                                                  Creditors   Judge       equity
                          Truste          Credit          '      or     holders'
Reasons for objecting          e  Debtor      or  committee   court    committee
------------------------  ------  ------  ------  ---------  ------  -----------
Lack of showing benefit       60      49      62         68      43           21
 to the estate
Total amount of fees in       27      32      29         28      26           14
 relation to value of
 estate
Duplication of services/      27      26      36         36      23           10
 efforts
Excessive hours worked        24      29      29         28      24            9
Insufficient description      24      19      33         31      30            6
 of the work done
Excessive hourly rates        16      20      28         30      24            7
 for the services
 performed
Excessive hourly rates        13      19      27         25      24            8
 for the persons
 performing those
 services
Charges for fee                9       9      15         13      12            3
 application preparation
Full hourly rates for         10      12      20         17      19            4
 travel time
Excessive lodging and          9       8      15         17      13            4
 travel expenses
Charges for amenities         10      10      12         14      11            3
 while on travel status,
 etc.
Charging in excess of          5       4       6          6       6            2
 the tax deductible
 amount in mileage
Parking fees while             6       5       8          7       8            3
 appearing in court
Not complying with            16      16      21         20      14            7
 formatting requirements
 for fee applications or
 requests for
 reimbursement of
 expenses
Not keeping time in           17      14      18         19      17            5
 appropriate increments
Not listing separately        20      18      26         26      22            6
 each task and the time
 required for that task
 ("lumping")
Inadequate documentation      16      13      21         21      18            4
 of expenses for which
 reimbursement is sought
Use of professionals to       12      10      11         14      12            4
 perform tasks which a
 paraprofessional could
 perform
Computerized research          6       5       8          8       9            3
 charges in excess of
 actual cost as billed
 to the professional
Overhead or any of the        10      10      17         15      13            3
 normally accepted
 components of overhead
Staff overtime                 8       7      11         11       9            3
Local meals for                9       8      11         11       7            3
 professionals or staff
 required to work during
 lunch or after hours
Word processing charges        6       6      10         11      11            3
Fax charges for sending        6       5       8          9      13            3
 or receiving a fax
 other than telephone
 toll charges
Unnecessary use of             6       5       8          9      14            3
 overnight delivery or
 messenger services
Reimbursement of               6       7       6          7       9            2
 creditors' committee
 out-of-pocket expenses
--------------------------------------------------------------------------------


                              Table IV.12
                
                 Professionals With Whom the Assistant
                 U.S. Trustees Experienced the Greatest
                      Problems in Chapter 11 Cases

                                                        Number  Percen
                                                            of    t of
Professional                                             AUSTs   AUSTs
------------------------------------------------------  ------  ------
Investment bankers/financial advisors\a                     17     18%
Accountants\b                                               13      14
----------------------------------------------------------------------
Note 1:  Responses reflected those professionals with whom the AUSTs
said they experienced great or very great problems. 

Note 2:  The total number of responses varied as follows: 

\a A total of 95 AUSTs responded to this question. 

\b A total of 96 AUSTs responded to this question. 



                              Table IV.13
                
                 Professionals With Whom the Assistant
                  U.S. Trustees Experienced the Fewest
                      Problems in Chapter 11 Cases

                                                        Number  Percen
                                                            of    t of
Professional                                             AUSTs   AUSTs
------------------------------------------------------  ------  ------
Management companies\a                                      55     58%
Attorneys\b                                                 51      53
Accountants\b                                               44      46
Investment bankers/financial advisors\a                     39      41
----------------------------------------------------------------------
Note 1:  Responses reflected those professionals with whom the AUSTs
said they experienced some or no problems. 

Note 2:  The total number of responses varied as follows: 

\a A total of 95 AUSTs responded to this question. 

\b A total of 96 AUSTs responded to this question. 



                              Table IV.14
                
                   Activities to Which Assistant U.S.
                     Trustees Gave Highest Priority

                                                        Number  Percen
                                                            of    t of
Activity                                                 AUSTs   AUSTs
------------------------------------------------------  ------  ------
Monitoring private trustees\a                               97    100%
Investigating fraud and misconduct allegations\a            82      85
Administrative matters\a                                    81      84
Responding to public inquiries\b                            74      77
Analyzing Chapter 11 disclosure statements\a                54      56
Analyzing Chapter 11 fee applications\a                     54      56
----------------------------------------------------------------------
Note 1:  Responses reflected those activities given high or very high
priority. 

Note 2:  The total number of responses varied as follows: 

\a All 97 AUSTs surveyed responded to this question. 

\b A total of 96 AUSTs responded to this question. 


   DIFFERENCES IN OFFICES WITH AND
   WITHOUT FORMAL GUIDELINES
-------------------------------------------------------- Appendix IV:2

As requested, we also compared differences in those offices without
guidelines and those offices with one or more types of formal
guidelines.  We found differences in the amount of staff's time spent
reviewing applications, the frequency of objections and informal
consultations, the professionals with whom AUSTs reported problems,
and the priority given selected activities. 

Specifically, 69 percent of the AUSTs whose offices had no guidelines
reported 10 percent or less of staff's time was spent reviewing
Chapter 11 fee applications.  In comparison, 22 percent of the AUSTs
whose offices had three forms of guidelines reported that 10 percent
or less of staff time was spent reviewing applications. 

One-third of the offices with all three forms of guidance reported
few objections to applications, while 79 percent of those with no
guidelines reported few objections.  Moreover, 21 percent of
respondents with no guidelines reported little informal consultation
occurred with professionals before fee hearings compared to 56
percent of those with all three types of guidelines.  Offices with no
guidelines reported fewer problems with accountants, attorneys, and
investment bankers/financial advisors than offices with one or more
types of guidelines.  The specific problems encountered, according to
some AUSTs included lumping and insufficient details regarding
services performed. 

We also asked the AUSTs about the priority given selected activities. 
A smaller proportion of those whose offices had no guidelines
reportedly gave high or very high priority to investigating fraud and
analyzing chapter 11 disclosure statements than those whose offices
had one or more types of guidelines.  Administrative matters,
monitoring private trustees, reviewing chapter 11 fee applications
and responding to public inquiries were each given about the same
level of priority by AUSTs with and without guidelines. 


ASSISTANT U.S.  TRUSTEES RESPONSES
REGARDING CHAPTER 7 CASES,
INCLUDING COMPENSATION AND
RETENTION OF PRIVATE TRUSTEES
=========================================================== Appendix V

As shown in table V.1, about 40 percent (44 of 97) of Assistant U.S. 
Trustees (AUSTs) reported that informal consultations on fee
applications occurred more than 80 percent of the time, but there was
considerable variation among respondents.  Formal objections to fee
applications were relatively infrequent, with about three-fourths of
AUSTs reporting they had formally objected in the past year to 20
percent or less of professional fee applications (see table V.2). 



                               Table V.1
                
                  Frequency of Informal Consultations
                    Prior to Chapter 7 Fee Hearings

                                                             Number of
Percent of time                                                  AUSTs
-------------------------------------------------------  -------------
1% to 20%                                                           14
21 to 40                                                            11
41 to 60                                                            17
61 to 80                                                            11
81 to 99                                                            30
100                                                                 14
----------------------------------------------------------------------
Note:  All 97 AUSTs surveyed responded to this question. 



                               Table V.2
                
                    The Percentage of Chapter 7 Fee
                Applications To Which the Office of U.S.
                       Trustees Formally Objected

                                                             Number of
Percent of applications                                          AUSTs
-------------------------------------------------------  -------------
None                                                                 4
1% to 20%                                                           67
21 to 40                                                            12
41 to 60                                                             8
61 to 80                                                             3
81 to 99                                                             1
100                                                                  2
----------------------------------------------------------------------
Note 1:  All 97 AUSTs surveyed responded to this question. 

Note 2:  AUSTs reported on average that 14 percent of staff time was
spent reviewing applications. 


   COMPENSATION AND RETENTION OF
   PRIVATE TRUSTEES
--------------------------------------------------------- Appendix V:1

Compensation of private trustees in chapter 7 cases is derived from
three basic statutory sources and is subject to certain statutory
limitations.  First, for each chapter 7 case, private trustees
receive a fixed amount of the total bankruptcy filing fee in each
case--$45 at the time of our survey.\1 Second, for work in chapter 7
asset cases--those with assets that can be liquidated to pay
creditors--the bankruptcy court may allow reasonable compensation for
actual and necessary services subject to a statutorily defined
maximum of estate receipts.  Third, with court authorization, private
trustees may receive income from self-retention as attorney or
accountant to perform certain duties outside their trustee
responsibilities.\2

Almost 90 percent of AUSTs reported that in more than 80 percent of
chapter 7 cases, judges routinely awarded the statutory maximum
compensation to private trustees (table V.3).  About 93 percent of
them believed that private trustee compensation should at least be
increased somewhat (table VI.4).  About two-thirds of AUSTs reported
that between one and seven private trustees voluntarily left their
positions in the past 2 years (table VI.5).  About 40 percent of
respondents believed that insufficient compensation was of little or
no importance as the reason that private trustees voluntarily left
their positions, while 31 percent believed it was of great or very
great importance (table IV.6).  Excessive paperwork was most
frequently cited as an important reason for trustee departures; 29
percent of respondents considered it of little or no importance,
while 35 percent considered it to be of great or very great
importance.  For those who remained in their positions, about 45
percent of AUSTs credited this to interesting and challenging work
and to bankruptcy work as a dependable source of income.  (See table
V.7.)

We also asked whether private trustees hired themselves or their law
firms as attorney for the trustee.  Such self-retentions can be an
additional source of income for private trustees.  Eighty-percent of
AUSTs reported that at least 61 percent of private trustees who are
attorneys have retained themselves or their law firm as attorney for
the trustee (see table V.8).  While a majority of private trustees
have at some point retained themselves or their law firm as attorney
for the trustee, they did not necessarily do so in the majority of
bankruptcy cases.  Only 38 percent of AUSTs reported that private
trustees retained themselves or their law firm in more than 60
percent of the cases (see table V.9). 



                               Table V.3
                
                  The Percentage of Cases That Judges
                 Routinely Awarded Private Trustees the
                       Statutory Maximum on Fees

                                                             Number of
Percent of cases                                               AUSTs\a
------------------------------------------------------  --------------
None                                                                 2
1% to 20%                                                            1
21 to 40                                                             2
41 to 60                                                             0
61 to 80                                                             6
81 to 99                                                            58
100                                                                 27
----------------------------------------------------------------------
\a There was one response of "unsure."

Note:  All 97 AUSTs surveyed responded to this question. 



                               Table V.4
                
                   Assistant U.S. Trustees Opinion on
                 Whether Private Trustees Compensation
                   Should Be Increased, Decreased, or
                         Remain About the Same

                                                             Number of
Opinion on compensation                                        AUSTs\a
------------------------------------------------------  --------------
Greatly increased                                                   28
Somewhat increased                                                  61
Remain about the same                                                2
Somewhat decreased                                                   2
Greatly decreased                                                    1
----------------------------------------------------------------------
\a There were two responses of "no opinion."

Note:  A total of 96 AUSTs responded to this question. 



                               Table V.5
                
                Assistant U.S. Trustee Responses on the
                     Number of Private Trustees Who
                Voluntarily Left Their Positions in the
                             Past Two Years

                                                             Number of
Number of trustees leaving                                       AUSTs
------------------------------------------------------  --------------
None                                                                31
One                                                                 18
Two                                                                 27
Three to seven                                                      16
Twenty-two\a                                                         1
----------------------------------------------------------------------
\a Because the turnover was unusually high, the results for this one
respondent are shown separately. 

Note:  A total of 93 AUSTs responded to this question. 



                               Table V.6
                
                The Most Important Reasons Cited For Why
                Private Trustees Voluntarily Left Their
                               Positions

                                                             Number of
Reasons for leaving                                              AUSTs
------------------------------------------------------  --------------
Requirements by the Executive Office for U.S.                       17
 Trustees\a
Caseload too heavy\b                                                 3
Income after expenses too low\c                                     20
Too much paperwork\d                                                23
Not paid in a timely manner\e                                        8
Retired\f                                                           13
----------------------------------------------------------------------
Note:  Responses reflected those reasons that were considered to be
of great or very great importance. 

\a A total of 64 AUSTs responded to this question. 

\b A total of 61 AUSTs responded to this question. 

\c A total of 65 AUSTs responded to this question. 

\d A total of 66 AUSTs responded to this question. 

\e A total of 60 AUSTs responded to this question. 

\f A total of 51 AUSTs responded to this question. 



                               Table V.7
                
                Important Reasons Cited for Why Private
                  Trustees Remained in Their Positions

                                                             Number of
Reasons for remaining                                            AUSTs
-------------------------------------------------------  -------------
Self-marketing opportunities\a                                      33
Prestige\a                                                          22
Interesting/challenging work\a                                      44
Financial rewards\a                                                 37
Dependable income for law practice or other                         43
 professional endeavor\b
Investment in time and equipment\c                                  15
----------------------------------------------------------------------
Note:  Responses reflected those reasons that were considered to be
of great or very great importance. 

\a A total of 94 AUSTs responded to this question. 

\b A total of 95 AUSTs responded to this question. 

\c A total of 93 AUSTs responded to this question. 



                               Table V.8
                
                 Percentage of Private Trustees Who are
                  Attorneys and Retained Themselves or
                 Their Law Firm as Attorney(s) for the
                                Trustee

                                                             Number of
Percent of panel trustees                                        AUSTs
-------------------------------------------------------  -------------
None                                                                 8
0.5% to 20%                                                          3
21 to 40                                                             2
41 to 60                                                             6
61 to 80                                                            14
81 to 99                                                            21
100                                                                 43
----------------------------------------------------------------------
Note:  All 97 AUSTs surveyed responded to this question. 



                               Table V.9
                
                  Percentage of Cases in Which Private
                 Trustees Retained Themselves or Their
                Law Firm as Attorney(s) for the Trustee

                                                             Number of
Percent of cases                                                 AUSTs
-------------------------------------------------------  -------------
None                                                                 9
1% to 20%                                                           43
21 to 40                                                             6
41 to 60                                                             2
61 to 80                                                            15
81 to 99                                                            19
100                                                                  3
----------------------------------------------------------------------
Note:  All 97 AUSTs surveyed responded to this question. 


--------------------
\1 Responses were based on the compensation maximums in effect in the
summer of 1993.  In 1994, legislation was enacted that increased the
maximums and raised from $45 to $60 the trustee payments from the
filing fees in each case. 

\2 More detailed information on private trustees income from all
three sources can be found in our report on professional fees in
chapter 7 cases entitled Bankruptcy Administration:  Case Receipts
Paid to Creditors and Professionals (GAO/GGD-94-173, July 13, 1994). 


MAJOR CONTRIBUTORS TO THIS FACT
SHEET
========================================================== Appendix VI


   GENERAL GOVERNMENT DIVISION,
   WASHINGTON, D.C. 
-------------------------------------------------------- Appendix VI:1

William O.  Jenkins, Jr., Assistant Director, Administration of
 Justice Issues
Robert L.  Giusti, Assignment Manager
William J.  Sabol, Senior Social Science Analyst


   LOS ANGELES FIELD OFFICE
-------------------------------------------------------- Appendix VI:2

Shannon Kessler, Evaluator


   DETROIT FIELD OFFICE
-------------------------------------------------------- Appendix VI:3

Henry L.  Malone, Regional Management Representative
Brenda J.  Trotter, Evaluator-in-Charge


   OFFICE OF THE GENERAL COUNSEL
-------------------------------------------------------- Appendix VI:4

Geoffrey R.  Hamilton, Attorney/Advisor


*** End of document. ***