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If a debtor fails to complete an approved course in personal financial management and the case is closed, does a trustee need to be reappointed to give the DSO notice upon entry of the discharge?

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If a debtor fails to complete an approved course in personal financial management and the case is closed, does a trustee need to be reappointed to give the DSO notice upon entry of the discharge?

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11 U.S.C. § 704(c)(1)(C) and 1302(d)(1)(C) require a trustee to send the discharge notice to both the DSO claimant and the State child support enforcement agency “at such time as the debtor is granted a discharge.” If the case is closed without the granting of a discharge because of the debtor’s failure to comply with the debtor education requirement, but the debtor subsequently complies and files the appropriate motion to have the case reopened so that a discharge can be entered, any order reopening the case should direct the United States Trustee to appoint a chapter 7 trustee so the proper DSO notice can be given.

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