Yes. In a recent Texas decision, the Creggett court disallowed the mortgage creditor’s claimed payment change from $1,246 monthly to $2,608 monthly, based on an asserted change in the Chapter 13 debtors’ monthly escrow account payment from $0.01 to $1,652. The court apparently believed that the creditor had not properly documented the analysis of the debtors’ escrow account.
In re Creggett, 2012 WL 6737813 (Bankr. S.D. Tex., Dec. 28, 2012), appeal filed, Case No. 4:13-cv-108 (S.D. Tex., filed Jan. 14, 2013)