N.Y. Surr. Ct. Proc. Act § 2114

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