The U.S. Trustee has begun to advance a novel argument that penalizes the beneficiaries of unsecured creditor trusts: that U.S. Trustee disbursement fees apply not only to disbursements made by debtors, but also disbursements made by creditor trusts formed under bankruptcy plans (commonly referred to as "GUC Trusts" or "Litigation Trusts"). Under 28 U.S.C. §1930(a)(6), the U.S. Trustee is entitled to a quarterly fee on any "disbursements" made by a debtor while its bankruptcy case remains open. While section 1930(a)(6) does not specify which entity must make these "disbursements," section 1930(a) indicates that "the parties commencing a case under title 11" must pay the enumerated fees.