This ambiguity arrived at the forefront of the bankruptcy bar’s attention through two cases that dealt with post-petition, pre-conversion increases in home values. Although these cases deal with post-petition appreciation in the context of conversion, they underscore the vast differences in how the bench approaches property of the estate in chapter 13.

With the U.S. Trustee Program announcing that § 341 meetings for all chapter 7 and 13 cases will be heading to Zoom, there is no turning back now. Most routine consumer bankruptcy cases can now be completed without the debtor ever leaving home.

Gone are the days of plastic grocery bags full of unopened mail from creditors. Gone are the days of printing hundreds of pages of bankruptcy schedules. Gone are the days of debtors listening to prior answers during § 341 meetings and simply parroting responses. Gone are the days of finding parking at the bankruptcy courthouse. Gone are the days of debtors finding it difficult to access a local or nearby attorney (a big win for access to the bankruptcy system). Gone are the days of wet-ink signatures (in some jurisdictions).