Consumer Bankruptcy Law and Practice: 14.4.4.4.6 Undisclosed fees and payment changes
In curing a default under section 1322(b)(5), the debtor makes payments under the plan on the prepetition arrearage and provides for the “maintenance of payments while the case is pending.” For a cure plan to be successful there must be full disclosure of all postpetition “maintenance” payments.473 Unfortunately, it has become common for mortgage creditors to add fees and charges to mortgage accounts without notice to the borrower, trustee, or bankruptcy court while the bankruptcy case is pending, without disclosing the fees in a proof of cla