To embed, copy and paste the code into your website or blog: The United States Bankruptcy Court for the Southern District of Texas recently clarified the administrative expense standard applicable to indenture trustees by holding that they can recover fees and expenses as administrative expenses only when they make a “substantial contribution.” This standard requires a greater showing than “benefit to the estate,” which is the general administrative expense standard. In re Sanchez Energy Corp., No. 19-34508 (Bankr. S.D. Tex. May 3, 2021). Background Sanchez”) issued two indentures for certain senior notes for which Delaware Trust Company (“ DTC”) acted as the successor Indenture Trustee. The confirmed chapter 11 plan called for payment in full in cash for holders of allowed administrative claims. The terms of the indentures indicated that DTC would be entitled to payment for fees and expenses, and that these fees and expenses may be classified as an administrative expense in a bankruptcy case.