In re Anderson, (Bkrtcy.D.Or.)

Plans - Debtors could require additional notice regarding mortgage escrow through Chapter 13 plan language.

Chapter 13 debtors could, through language in their proposed plan, require their residential mortgage lender to provide notice to the Chapter 13 trustee and the debtors' counsel, in addition to the debtors, about changes in the escrow amounts required and about any shortages, deficiencies, or surplus of funds held in escrow. The additional notice was more in the nature of a procedural requirement to aid case administration than an impermissible modification of the lender's rights, and the debtors' deemed authorization of such notices under a local rule insulated the lender from automatic stay violations.