policy owned by the debtor is not easily answered. This is especially so in the case of a D & O policy. Such policies typically provide direct protection to the corporation’s directors and officers. Indirect coverage is often afforded to the corporation for losses incurred indemnifying its principals. And some policies provide direct protection to the company (sometimes referred to as “entity coverage”) for certain kinds of claims, e.g., violations of securities law. Some cases have held that such proceeds are property of the estate either' because the debtor owns the policy, the debtor is a named insured under the policy, or because the estate would simply benefit from including the proceeds. See In re Sacred Heart Hospital of Norristown, 182 B.R. 418, 419-20 (Bankr.E.D.Pa.1995) (<HOLDING>); In re Circle K Corp., 121 B.R. 257
holding that existence of indemnity coverage notwithstanding that debtor had paid any such claims on behalf of principals operated nevertheless to bring proceeds into estate in order to avoid diminution of assets holding that where the policy includes indemnification coverage to the corporation proceeds are not property of the estate where there is no proof of payments by corporation of payments holding that existence of entity coverage was sufficient to bring proceeds into estate notwithstanding absence of claim against debtor corporation holding that because no claims had been filed against the debtor existence of entity coverage did not make proceeds property of the estate holding that entity coverage inapplicable because there were no remaining securities claims against the debtor