Del. C. » Title 12 — Fiduciary Relations · CHAPTER 35. Trusts · Decedents’ Estates and Fiduciary Relations
Delaware Code

12 Del. C. § 3522 (2026)

Trustees’ accounts for inter vivos trusts

✓ current as of May 2026
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Trustees of an inter vivos trust (whether or not property was bequeathed or devised to such trust by a testamentary disposition) shall not be required to file any accounts or inventories with respect to such trust, except:

(1) To the extent provided in the governing instrument;

(2) Upon an order of the Court of Chancery, for cause shown, expressly requiring an accounting by such trustees; or

(3) If such trustees were appointed by the Court of Chancery, then as may be otherwise provided in the order of appointment.

79 Del. Laws, c. 352, §  4; 
Notes of Decisions
Cited in 2 cases (1 in the last 5 years), 2015–2021 · leading case: In the Matter of the Jeremy Paradise Dynasty Trust & The Andrew Paradise Dynasty Trust (Del. Ch. 2021).
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In the Matter of the Jeremy Paradise Dynasty Trust & The Andrew Paradise Dynasty Trust (Del. Ch. 2021). “51 12 Del. C. § 3522(2). 52 See Ughetta v. Cist, 2015 WL 3430094 , at *15 (Del.”
Margaret C. Ughetta v. Mary Harding Cist, individually, as of Est. of John David Cist, & as Tr. of the Supp Trust Agreement of John David Cist (Del. Ch. 2015). “130 See 12 Del. C. § 3522(2). See also 1A C.J.S. Accounting § 44.”
— 12 Del. C. § 3522(2) — 2 cases
In the Matter of the Jeremy Paradise Dynasty Trust & The Andrew Paradise Dynasty Trust (Del. Ch. 2021). “51 12 Del. C. § 3522(2). 52 See Ughetta v. Cist, 2015 WL 3430094 , at *15 (Del.”
Margaret C. Ughetta v. Mary Harding Cist, individually, as of Est. of John David Cist, & as Tr. of the Supp Trust Agreement of John David Cist (Del. Ch. 2015). “130 See 12 Del. C. § 3522(2). See also 1A C.J.S. Accounting § 44.”
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