When is a creditor's failure to process late filed claims an acceptable reason for denying late claims?

The orderly and efficient administration of an equity receivership is certainly an acceptable reason for denying late filed claims, if that purpose is served and there are no overriding competing considerations. SEC v. Wencke, 783 F.2d 829, 837 n. 9 (9th Cir.1986). Here, the late claims were few in number and small in amount. Processing them would not have amounted to an administrative burden. At least four of the five late claims were filed before the deadline for objections to classification of filed claims, a date before which disbursements could not even have been finally computed. Inasmuch as accepting these few late claims could not have required recomputation of the final disbursement formula, let alone have delayed any actual planned disbursements, I fail to see how their acceptance could have affected the "expeditious administration" of the receivership.