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Can My CPA or Bookkeeper Handle Subchapter V Reporting, or Do I Need a Financial Advisor?

Juwon Lee8 min read

Summary

In a Subchapter V case, your CPA or bookkeeper usually cannot handle the 13-week cash flow, the projection lines of the monthly operating report (Form 425C), or the plan projections, unless they have built them in a filed case. The books and the tax return stay with them. In our review of 213 Subchapter V cases filed in late 2025, 59 of the 66 confirmed debtors whose reports we could see had filed their monthly reports on time.

Those three documents have to agree with each other, and they are separate work, usually done by someone trained in restructuring. The four questions at the end of this page will tell you whether the person you have can do it.

The 13-week cash flow: a weekly model tied to the bank

It is a week-by-week model of cash coming in and going out, tied to the bank balance at the start and at the end. An annual budget split into thirteen columns does not do that.

Collections come from the receivables aging, customer by customer. Payments come from the payroll calendar, the rent and tax due dates, and the vendor terms. Each assumption is written down so that the lender, the trustee, or the court can check it.

Every week the forecast is put next to what happened, and each material miss gets a one-line explanation. That weekly test is what makes next week's forecast believable.

A cash collateral order or a DIP budget sits on top of this model. Once the order approves the budget and sets a permitted variance, the budget is a term of a court order.

Forecasting cash by the week and being checked on it every week is a skill people learn doing restructuring work.

The monthly report: its projection lines come from the forecast

Part 7 of Form 425C (lines 32 through 37) puts last month's projection beside this month's actual receipts, disbursements, and net cash flow, and then asks for next month's projection.1 Those lines come out of a cash forecast. Without one they are left blank or filled in after the fact, and both are easy to see.

Line 19, opening cash, has to equal line 23 of the prior report. Line 23 should be backed by a bank reconciliation, which the form lists as an attachment and some U.S. Trustee offices require. When that chain breaks, the U.S. Trustee's office calls.

The debtor's responsible party signs the report under penalty of perjury. An unexcused failure to file required reports on time is also one of the listed grounds for converting or dismissing the case.2

If the monthly projections came true within an explained margin, the plan can point to them as evidence. If they missed, the plan projections start out hard to believe.

Weak plan projections are where confirmation gets contested

The court has to find that the plan is feasible.3 For a nonconsensual Subchapter V plan it also has to find that the plan commits the debtor's projected disposable income for three to five years, and that the debtor will be able to make the payments, or is reasonably likely to and the plan provides remedies if it does not.4

The Subchapter V trustee, the U.S. Trustee, and the creditors read the projections against the monthly reports already on the docket. Where the plan's assumptions do not match what the reports show, that is where the objection lands.

The result is a delayed confirmation or a denied one. Every added month adds professional fees to an estate that is already short, and failure to file a plan within the time the Code allows, or to confirm one within a time the court sets, is itself a ground for conversion or dismissal.2 A Subchapter V debtor has 90 days from the order for relief to file its plan.5

After confirmation the debtor lives on that budget for the life of the plan, which is three to five years when the plan is confirmed without the creditors' consent.

By the U.S. Trustee Program's count, 52% of Subchapter V cases filed in fiscal years 2020 through 2023 reached a confirmed plan, 32% were dismissed, and 13% were converted.6 Many of the cases that ended early had no business left to reorganize, and better reporting would not have saved them. For the cases that do have a business, reporting matters. In one 2024 case the court converted a Subchapter V debtor to Chapter 7 after monthly reports came in late month after month and the plan was filed without the projections the Code requires.7

We also followed 213 Subchapter V cases filed nationwide between November 1 and December 9, 2025, through their dockets to October 6, 2026.8 Of the 66 confirmed cases whose reports we could see, 59 (89%) had filed their monthly operating reports on time. In courts that publish every docket entry, 13 debtors never filed a report, and none of them reached confirmation.

This does not prove the reports caused the outcome. A failing business also stops reporting. But the debtors that reached confirmation had, almost all of them, filed on time. Someone has to build that run, and the cash forecast behind it, from the first week.

What the bookkeeper and the CPA do in the case

The bookkeeper closes the books, runs payroll, payables and receivables, and produces the detail behind the bank reconciliations. The CPA files the tax returns and prepares year-end statements. Both keep that work.

We take their output and prepare the 13-week model, the monthly operating report, the cash collateral budget, and the plan projections, and we answer the trustee's and the lender's questions about the numbers. We take the case reporting.

Four questions to ask before you hand over the reporting

  1. Have you prepared and filed Form 425C in a case, and for how many months?
  2. Have you kept a 13-week cash flow tied to the bank, updated it weekly, and explained the variances?
  3. Have you built plan projections for a case that went to confirmation, and can you show the assumptions tied to the monthly reports?
  4. Who is responsible for making the three documents agree?

If the answer to all four is yes, hire that person, whatever their title.

Samples and fees

Look at how the three documents connect in our sample 13-week model, sample monthly report package, and sample plan budget model. Fees are fixed and published; the report alone is $1,500 a month through our monthly operating report service for Subchapter V debtors. To talk about a case, contact us.

Footnotes

  1. Official Form 425C, Monthly Operating Report for Small Business Under Chapter 11 (12/17). https://www.uscourts.gov/forms-rules/forms/monthly-operating-report-small-business-under-chapter-11 ↩

  2. 11 U.S.C. § 1112(b)(4)(F) and (J). https://www.law.cornell.edu/uscode/text/11/1112 ↩ ↩2

  3. 11 U.S.C. § 1129(a)(11), applied in Subchapter V by § 1191(a) and (b). https://www.law.cornell.edu/uscode/text/11/1191 ↩

  4. 11 U.S.C. § 1191(c)(2) and (3). https://www.law.cornell.edu/uscode/text/11/1191 ↩

  5. 11 U.S.C. § 1189(b). https://www.law.cornell.edu/uscode/text/11/1189 ↩

  6. U.S. Trustee Program, Chapter 11 Subchapter V Statistical Summary. Cases filed in U.S. Trustee districts in fiscal years 2020 through 2023, dispositions through December 31, 2024; 3% were still pending. Alabama and North Carolina are not included. https://www.justice.gov/ust/subchapter-v ↩

  7. In re United Safety and Alarms, Inc., No. 23-14861-SMG (Bankr. S.D. Fla. Mar. 6, 2024). https://www.govinfo.gov/content/pkg/USCOURTS-flsb-0_23-bk-14861/pdf/USCOURTS-flsb-0_23-bk-14861-0.pdf ↩

  8. Lee Restructuring Advisors, docket review of 213 Subchapter V cases filed November 1 through December 9, 2025, followed through October 6, 2026. Method, limits, and the case list: How we counted. ↩

Questions

Can my CPA do the monthly operating reports?
Yes, for the form itself. The harder part is Part 7 of Form 425C, which puts last month's projection next to this month's actual and then asks for next month's projection. Those lines come out of a cash forecast. If there is no forecast, they get filled in after the fact or left blank.
Do I need a financial advisor in a Subchapter V case?
The Bankruptcy Code does not require a debtor to hire one. In practice, someone has to build the three documents and keep them consistent. If your CPA has done that in a filed case, you do not need anyone else. If not, you need someone who has.
What does a financial advisor do that a bookkeeper or CPA does not?
Mostly the forecasting. The advisor builds the next thirteen weeks of cash, checks it against the bank every week, and uses the same numbers for the cash collateral budget and the plan projections. The bookkeeper's books and the CPA's returns feed all of it.

Further reading

General information for professionals, not legal, tax, or investment advice. Rules, forms, and local practice change; confirm current requirements with the court and the U.S. Trustee for the district. Disclaimer