24bk09311 and 24bk14211
Ch. 13 Debtors objected to servicers’ claims for projected escrow shortages, arguing the claims were not prepetition defaults. HELD: Under the bankruptcy code and rules, as well as RESPA (the relevant nonbankruptcy law), escrow shortages are prepetition claims. Escrow analysis must be done as of the petition date—including in a case converted from chapter 7. Objections overruled, except that Lakeview may amend its claim to be consistent with the holding.