What a No-Look Fee Is
A no-look fee is a flat dollar amount that a local bankruptcy court treats as presumptively reasonable for routine Chapter 13 debtor-representation work. If the fee matches the local presumptive amount and the work is limited to the scope covered by the presumption, the court approves it without line-by-line review.
Common labels: "presumptive fee," "no-look fee," "flat fee," "simplified fee arrangement," "standard Chapter 13 fee." All refer to the same mechanism.
The authority for presumptive fees derives from Section 330(a) (reasonable compensation) and local bankruptcy court rules or standing orders. The presumption is designed to reduce administrative burden on routine cases; it is not a statutory requirement.
Typical No-Look Fee Ranges (General Benchmarks)
Amounts vary significantly by district. The ranges below reflect broad market practice; always check the specific district's local rules, fee guidelines, or standing order.
| Market Type | Typical Presumptive Fee | Notes |
|---|---|---|
| Rural/consumer districts | $3,500 - $4,500 | Often includes filing fee reimbursement separately |
| Mid-size urban markets | $4,000 - $5,500 | May include post-confirmation modifications up to a cap |
| Major metropolitan areas | $5,000 - $7,500+ | Some districts have tiered structures based on plan complexity |
| Business or complex consumer cases | Exceeds no-look, requires application | Courts typically require fee application under Rule 2016(a) when fees exceed the cap |
Check the current local rule or standing order for the specific district. Amounts change periodically.
What the No-Look Fee Typically Covers
The scope of work included in a presumptive fee usually extends from pre-filing counseling through confirmation, plus a defined set of routine post-confirmation services. A typical scope of "basic" Chapter 13 services:
- Pre-filing consultation and case evaluation
- Preparation of the petition, schedules, Statement of Financial Affairs, and means test
- Preparation of the Chapter 13 plan
- Representation at the Section 341 meeting of creditors
- Routine confirmation-hearing preparation and appearance
- Responding to standard trustee requests for documents
- Handling routine motion practice (e.g., standard motions to value collateral, routine claim objections)
- Some portion of post-confirmation plan monitoring
What the No-Look Fee Typically Does Not Cover
Most local rules expressly carve out non-routine work from the presumptive fee. Extra work requires a separate fee application under Rule 2016(a):
- Contested confirmation (objections requiring evidentiary hearing)
- Adversary proceedings under Rule 7001 (dischargeability, lien stripping outside routine, nondischargeability defense)
- Motions for relief from the automatic stay requiring evidentiary response
- Contested claim objections beyond routine
- Plan modifications requiring re-notice and hearing
- Motions to redeem, reaffirm, or lien-strip requiring valuation hearings
- Tax-related litigation
- Discharge-related disputes
Red flag: An attorney who takes the full no-look fee and then bills separately for work that was supposed to be included (e.g., routine 341 meeting appearances or standard confirmation) is double-billing.
How Disclosure Works for No-Look Fees
The no-look presumption does not eliminate the Rule 2016(b) disclosure requirement. Debtor's counsel must still file the statement of compensation disclosing the fee arrangement, source of payment, and any sharing arrangement.
If the attorney is charging at the no-look amount, the Rule 2016(b) disclosure should:
- State the amount of the flat fee
- State that the fee is being charged pursuant to the local presumptive fee structure
- Identify the portion paid pre-petition vs. through the plan
- Identify any supplemental fee arrangements (e.g., payment for excluded services if they arise)
- Be supplemented if the arrangement changes
When No-Look Fees Can Still Be Challenged
The "no-look" presumption is a procedural shortcut, not a statutory shield. A flat fee can still be reviewed under Section 329(b) if the fee exceeds the reasonable value of services rendered. Common challenge scenarios:
Scenario 1 - Case dismissed before confirmation
Attorney charged full no-look fee; case was dismissed at the 341 meeting or on an early trustee motion to dismiss. Services actually rendered (consultation, petition filing) are a fraction of what the presumption assumes. Courts have reduced no-look fees where the case never progressed to confirmation. See services-rendered vs services-charged audit.
Scenario 2 - Attorney collected no-look fee plus additional undisclosed retainer
Attorney files a 2016(b) disclosure reporting the no-look fee, but also collected a separate cash retainer outside the docket. This is a disclosure violation - the remedy is disgorgement of the undisclosed amount under Section 329(b) regardless of whether the no-look fee itself was reasonable.
Scenario 3 - No-look fee is taken, but work is minimal
Debtor files pro-se-style boilerplate schedules; attorney performs no meaningful case analysis, no plan drafting, no 341 appearance preparation; but bills the full presumptive fee. This is challengeable under Section 329(b) as compensation exceeding reasonable value.
Scenario 4 - Conversion to Chapter 7 after collecting full Chapter 13 fee
Attorney collects the no-look Chapter 13 fee, case converts to Chapter 7 before confirmation, and attorney continues in Chapter 7 representation. The portion of the fee allocable to work that was never performed (confirmation, plan monitoring, discharge, post-confirmation services) is recoverable.
How to Challenge a No-Look Fee
The mechanics of a no-look fee challenge mirror the general Section 329(b) motion structure:
- Pull the 2016(b) disclosure. Confirm what was disclosed and what fee arrangement was represented.
- Reconstruct services rendered. Review the docket for appearances, filings, responses. Compare to what the presumption is supposed to cover.
- Identify the delta. Where services are materially less than the presumption contemplates, the excess is recoverable under 329(b).
- Motion under Section 329(b) (or Rule 2017 sua sponte request). The motion asks the court to review whether the presumptive fee continues to represent reasonable value in this case.
- Remedy: reduction to amount reasonably commensurate with actual services; return of excess to debtor or estate.
See motion template for structural guidance. The worked examples page illustrates how to compute specific reductions.
Special Considerations
"Pot" Plans
Some Chapter 13 plans pay attorney fees "through the plan" over the life of the plan (often 36-60 months). Debtors who ultimately cannot complete the plan may be paying on an attorney fee for services that were not reasonably rendered. The presumption is reviewable at any time under Section 329(b).
Pre-Petition Retainer Plus Plan Payments
Some arrangements combine an up-front pre-petition retainer with plan payments totaling the full presumptive amount. Both tranches are compensation and must be disclosed under Rule 2016(b). Undisclosed pre-petition retainer is an independent violation.
Multi-Case Referral Arrangements
Some high-volume Chapter 13 practices operate on a referral/volume model that aggregates cases. The presumption does not excuse the attorney from individualized review in each case. Where a mill-style practice is collecting presumptive fees without individualized service, the UST and trustees have authority to examine aggregate patterns.
Questions to Ask Your Chapter 13 Attorney
- What is the presumptive/no-look fee in this district, and how much are you charging?
- What services are included in the flat fee? What is excluded?
- How much do I pay up-front, and how much is paid through the plan?
- Will you file a Rule 2016(b) disclosure, and can I see a copy?
- What happens to the fee if my case is dismissed before confirmation?
- What happens to the fee if we need to convert to Chapter 7?
- Are there any additional charges I should expect (e.g., for motions, adversary actions, plan modifications)?