Issue link: https://mbozikis.ufcontent.com/i/1422521
35 also be served upon the U.S. Trustee. A professional that fails to obtain court approval prior to employment may forfeit the right to compensation. See In re Integrity Supply, Inc., 417 B.R. 514, 518– 19 (Bankr. S.D. Ohio 2009). However, this can be avoided in certain circumstances, as bankruptcy courts are empowered to grant nunc pro tunc retention orders, discussed in greater detail in Chapter III.E.1. above. An attorney representing a debtor-in- possession must also obtain court approval prior to its retention, but an attorney need not obtain court approval when representing a debtor in a liquidation case under Chapter 7, in a Chapter 13 case, or pursuant to its representation of a debtor that is not in- possession in a Chapter 11 case. In re Designaire Modular Home Corp., 517 F.2d 1015 (3d Cir. 1975). In addition to the professionals retained pursuant to Section 327 discussed above, the trustee may seek to continue to employ (i) so-called "ordinary course professionals" or (ii) professionals who are not considered "professional persons" within the meaning of Section 327 because they do not play an intimate role in the reorganization of the estate. See In re Johns- Manville Corp., 60 B.R. 612, 620–21 (Bankr. S.D.N.Y. 1986). Ordinary course professionals are typically professionals who are assisting the trustee with one or a few specific, segregated matters, such as a particular litigation, transaction or regulatory regime, and whose monthly fees for such work are within certain preapproved monthly maximum amounts. The trustee typically will seek authorization to employ and compensate ordinary course professionals pursuant to Sections 327(e), 328, 363(c)(1) and 1108 of the Bankruptcy Code. However, given their limited role and cost, the retention and compensation procedures for such professionals are often more streamlined and less burdensome than for professionals who are playing a much larger role for the debtor. Furthermore, courts have held that other parties do not fall within the scope of "professional persons" to be retained under Section 327(a), and thus do not require prior court approval under Section 327(a). Such parties include, but are not limited to: environmental