N.Y. Surrogate's Court Procedure Act § 2114 (2026)

§ 2114. Review of compensation of corporate trustee
  1. At any time during the administration of a testamentary or lifetime
trust and irrespective of the pendency of a particular proceeding, the
court may review the reasonableness of the compensation determined by
the corporate trustee for the trustee's own services. Any corporate
trustee who has received excessive compensation from a trust may be
ordered to make appropriate refunds.
  2. A proceeding may be instituted by petition of a corporate trustee
of the trust or any person interested in the trust. No accounting shall
be required in such proceeding.
  3. No trustee shall be liable or accountable for any commissions paid
to another trustee hereunder which a court orders to be refunded to the
trust or any person interested in the trust.