Section 1104(c)(2) provides, in relevant part, as follows:

[O]n request of a party in interest or the United States trustee, . . . the court shall order the appointment of an examiner to conduct such an investigation of the debtor as is appropriate, including an investigation of any allegations of fraud, dishonesty, incompetence, misconduct, mismanagement, or irregularity in the management of the affairs of the debtor of or by current or former management of the debtor, if—

In general, over the past several years investing in bankruptcy claims has become increasingly challenging. One reason for this is because there are fewer and fewer cases that result in distributions to unsecured creditors. Retail bankruptcy cases, which have historically been good sources of bankruptcy claims for claims investors because they have many vendors, have been wipeouts. For example, such cases as Bed Bath & Beyond Inc., Party City Holdco. David’s Bridal LLC and Tuesday Morning Corp. all have provided no recovery for general unsecured creditors. Other cases, such as Sears Holding Corp., have only provided a recovery to administrative expense unsecured creditors — creditors that provided goods to a debtor within 20 days prior to the bankruptcy filing date or post-petition.