to those of a trustee in bankruptcy. Compare Wis. Stat. §§ 128.13, 128.14, and 128.17 (describing receiver's duties in state receivership proceedings), with 11 U.S.C. §§ 704,1106 (listing duties of a trustee in federal Chapter 7 and Chapter 11 bankruptcy proceedings). 7 Before the Ninth Circuit Bankruptcy Appellate Panel issued Mayan Networks, several other courts had observed that collateral securing letter of credit proceeds are property of the estate. See Kellogg v. Blue Quail Energy, Inc. (In re Compton Corp.), 831 F.2d 586, 590-91 (5th Cir. 1987); see also American Bank v. Leasing Service Corp. (In re Air Conditioning, Inc.), 845 F.2d 293, 296 (11th Cir. 1988). Others held that letter of credit proceeds a . (In re S-Tran Holdings, Inc.), 414 B.R. 28, 33-34 (Bankr. D. Del. 2009) (<HOLDING>). 8 For example, the court in Willis v. Celotex
holding that a trustees interest in letter of credit proceeds acting as a security deposit is property of the estate holding that because proceeds of a letter of credit were not secured by estate collateral the proceeds were not property of the estate holding the real estate sale proceeds holding that where the policy names only the directors or officers as insured the proceeds are not property of the estate holding that the proceeds of a liability insurance policy were not property of the estate