With no explanation, chose the best option from "A", "B", "C" or "D". needs of creditors for certainty that they will not be required to return payments received prior to conversion is reached by holding that a creditor obtains a vested right to the funds in a plan account when the funds are disbursed to the creditor by the trustee. See In re Luna, 73 B.R. 999, 1002 (N.D.Ill.1987) 4. The Trustee’s duties post-confirmation include the distribution of funds on hand. The Pegues, Hardin, and Galloway decisions, supra, observed that a chapter 13 trustee is required to perform certain statutory duties after the case is converted. These duties include the filing of a final report pur ) (finding property acquired by chapter 13 debtor before conversion is property of chapter 7 estate). Contra Bobroff v. Continental Bank (In re Bobroff), 766 F.2d 797 (3d Cir.1985) (<HOLDING>). 4 . See 4 Keith M. Lundin, Chapter 13

A: recognizing that a debt ors sequential filing of a chapter 7 petition and then a chapter 13 petition is the socalled chapter 20 
B: recognizing the distinction between the reorganized debtor and the converted debtor and holding an asset which was not property of the original chapter 11 estate does not become property of the converted chapter 7 estate
C: holding that a debtor was not acting in bad faith when he converted a case under chapter 7 to a case under chapter 13 for the purpose of discharging a debt for fraud but it was a fact which could be considered
D: holding tort action accruing after original chapter 7 petition not part of estate when case converted to chapter 13 and then back to chapter 7
D.