Mortgage Servicing Fraud
occurs post loan origination when mortgage servicers use false statements and book-keeping entries, fabricated assignments, forged signatures and utter counterfeit intangible Notes to take a homeowner's property and equity.
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Can anyone clarify how the UCC affects foreclosure.  I understand that the note is transferred by endorsement and delivery.  My big question is with regards to the mortgage.  Does article 9 automatically perfect the mortgage?  Do you still have to assign the mortgage to the purchaser in recording states?  What happens to state law when the UCC says a sale of the note carries with it the mortgage and a state requires the Mortgage and assignments be recorded which MERs doesn't do? 


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William A. Roper, Jr.
Mike, negotiation of a negotiable instrument under UCC 3 is by indorsement and delivery.  Look to the black letter law and cases of the jurisdiction where the instrument was executed to determine the specific law as to the negotiable instrument.  You should look to the law of the place of delivery to ascertain the law to apply to the negotiation.

Under the common law almost everywhere, the negotiation of a promissory note carries with it the right to enforce the security instrument.  But this may not actually be the case with MERS mortgages, as there seems to have been a bi-furcation of the note and mortgage possibly vesting the mortgage in MERS.

You need to very carefully study the cases, particularly those authoritative in your jurisdiction, to ascertain whether the lien secured by an MERS mortgage actually follows the note.

When discussing the legal requisites of mortgages, deeds of trust, security deeds and/or other mortgage security instruments, it is important to bear in mind that the law varies widely from state to state.  Usually, the minimum requisites of a valid mortgage, deed of trust, security deed and/or other mortgage security instrument are set forth within a state's statute of frauds.

In most places, the rights conveyed within a mortgage assignment (or the assignment of a deed of trust) are effected by the valid execution of an instrument by a grantor (with a valid interest) consistent with the statute of frauds.  But the assignment (like a deed or mortgage) is said to be perfected by recording.  The requisites of recording are set forth within a state's recording acts.

A key thing to understand about the recording acts is that recording is not usually necessary in order to make the deed valid, but rather serves to put others on notice as to the claimed interest and affords a basis for determining the rights of competing parties to the same interests in those instances where the same or similar interests are granted to more than one person or entity.

This is easiest to understand in terms of deeds.  If SMITH grants a deed conveying "Blackacre" to JONES on January 1, 2010, and then later also grants a deed to BAKER on July 1, 2010, the recording acts help to determine whether JONES or BAKER has the winning valid deed.

Under the common law, the rule is "first in time, first in right".  So under the common law, JONES has the valid deed and title to Blackacre under the basic facts described above.

The recording acts displace the common law and impose some duty upon grantees to perfect their interest by recording.  There are several variants of the basic recording act rules, but generally speaking a grantee perfects its interest by immediately recording (or at least recording BEFORE the grants of other competing deeds).

Suppose that JONES purchases "Blackacre" from SMITH on January 1, 2010, but fails to record.  If BAKER subsequently purchases Blackacre from SMITH, without notice of the prior deed to JONES and innocently believing (in reliance upon the public records) that SMITH is still the owner, then the recording acts would generally give BAKER's claim priority over that of JONES, even though JONES had the first (and otherwise valid) deed.

As mentioned, there are a variety of nuances and specific treatments of various factual situations set forth in various implementations of the recording acts.  This is a bare bones explanation.

But a key idea to bear in mind is that the recording acts usually have NO APPLICATION to the question as to whether SMITH's deed to JONES is valid as between SMITH and JONESThe recording acts only pertain to whether another competing deed is valid in respect of a failure of the first grantee to record.


As applied to assignments then, the question presented is usually NOT whether recording gives effect to the assignment (though recording with a public registry can help to overcome questions as to the date of the instrument in respect of widespread forgery and fabrication of instruments).  Rather, the recording would establish whether one or another competing assignment should be given priority and legal effect.  If there are no competing assignments, recording becomes irrelevant.


One exception of which I am aware to the general rule with respect to the necessity of recording is the rule in Ohio, where apparently recording is a necessary pre-requisite to foreclosure.  I am unaware of any other state where recording is required, though I have not surveyed all jurisdictions.


Those who point to the failure of a plaintiff to record are probably making an ineffective and possibly legally invalid argument (except in Ohio).  But there are also related defensive arguments.

Very often, the foreclosure mills working for mortgage servicers create a forged assignment either shortly before or shortly after commencement of suit.  Through thorough discovery and use of a good expert witness, the assignment can be proven to be a forgery.  While the focus has to date been on robo-signing and/or the authority of the person executing, even this focus has often been misplaced.  What makes the document a forgery is not the fact that it was hastily signed or improperly executed (though these may be contributing factors).  Rather, the KEY is the fact that the forgery purports to memorialize a transaction which never actually took place.
Most often, the assignment was created solely for use as false evidence in the foreclosure suit and proof of the forgery should be an effective means of showing the plaintiff's fraud on the court and unclean hands!

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Is it possible for a NY trust to take bearer paper from an endorsement in blank?  And if the servicer is holder the bearer paper for the "trustee" of the trust. 

Because if that were the case they would be able to co-mingle the notes to
other trusts for which they are acting as a "trustee".  I've haven't seen this argument in any pleadings so far, is this a valid argument?
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all questions

So what happens when the lender on the mortgage is no longer around and no assignment is recorded?  How is Mers still a nominee for someone that isn't around?  What would they have to show proving the note was transferred?  You see assignments from Mers all the time from lenders out of business to trusts.  How can they do that?  Mers may still be the Mortgagee as nominee for the new holder of the note (according to their policy) but that severs the nominee relationship with the orginator or does it?  Mers says they are acting for the note holder.  Does it even matter if the note holder doesn't have the mortgage if the recording isn't required to enforce the mortgage?  Has a burification of the note and mortgage been argued sucessfully?  I read the Mers VP deposition and I think I'm more confused than before I read it. 

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William A. Roper, Jr.

Adam LEVITIN, a noted Georgetown University Law professor makes precisely this argument rather articulately in a post at Credit Slips:


"Fisking the American Securitization Forum's Congressional Testimony"


Although I believe that LEVITIN's argument seems compelling, particularly on public policy grounds (indorsement in blank seems to invite possible comingling and mischief where one trustee is serving in this role for many institutional trusts), I also believe that LEVITIN's argument fails for several reasons, which I have not yet posted as comments to his post (I really do NOT like making the argument for the other side).


First, if one carefully checks the trust indentures, PSAs and registration statements, most of these do NOT specify that the trusts are either New York trusts or subject to New York trust law.  To the contrary, many of the trusts are described as Delaware trusts.  So right off the bat, one probably needs to brush off Delaware trust law to see whether the arguments can gain traction.


Second, I believe that LEVITIN's argument imputing some requirement that every negotiation requires an indorsement, though aggressive, is a bit of a tortured reading of the PSA/registration statement language.  Indorsement in blank is expressly ALLOWED under the UCC and thereby delivery of the instrument is ALL that is thereafter typcially required to accomplish negotiation.


I DO believe that delivery needs to be PROVEN by affirmative primary evidence and that conclusory statements by persons lacking personal knowledge will NOT DO.  The Best Evidence Rule would require that the party seeking to prove delivery either produce a witness to the delivery (who can actually testify that they RECALL the delivery of that particular instrument amongst millions) OR a the production of a delivery receipt.  The hearsay testimony of a person who asserts that the instrument was delivered because they have checked the business records and these records reflect delivery is insufficient.  


Third, the argument that the belated delivery of the promissory note or belated assignment of mortgage cannot effect a valid conveyance seems to me to be a pretty shakey argument absent some specific state statutory prohibition.


Permit me to illustrate by way of analogy.  Suppose that we entered into a contract of sale providing for the sale of a parcel of real estate and calling for closing as of a particular date.  The date might very well be of central importance because it might affect the tax consequences of the transaction (either as to eligibility for some preferential tax treatment or the determination as to which tax year the transaction falls for one or both parties).


Further suppose that due to delays in financing or some other reason the transaction fails to close on the contemplated date.  But further suppose that despite the contractual provisions specifying that time was of the essence and specifying the closing date that a later closing took place, which closing was memorialized by an otherwise valid deed, transfer of the consideration, execution of a note, mortgage, HUD-1 Settlement Statement, etc.


Can another non-party to the closing transaction subsequently argue that the conveyance is invalid because it didn't take place as expressly shown within the argeement of sale?


Common sense indicates otherwise.  The delay would seem to have been waived by both parties.  There may very well be unfavorable tax consequences as a result of the delay, but these adverse tax consequences are independent of the question as to the validity and legitimacy of the conveyance.




So I believe that the argument that a belated conveyance into the trust is invalid is NOT going to prove to be a winning argument where the plaintiff actually UNDERSTANDS the law and the facts and makes a compelling argument.


But I also believe that this is the incorrect argument for another different reason, and this is something that distinguishes my position from many other foreclosure defense advicates.  Others look at the evdience of the belated assignment and see an untimely conveyance.


I look at this assignment and see a forged instrument which conveys nothing at all and which was fabricated solely for use as false evidence in the foreclosure.  And so instead of focusing on trying to prove that the instrument was invalid, through tardiness, I would be seeking to prove that the instrument itself was a forgery and a fraud upon the court.


With good discovery and a strong expert witness, I believe that this can be done in a startling number of cases.




I would certainly encourage you to further research and explore Adam LEVITIN's arguements and to MAKE THESE arguments if you believe that they fit the facts of your case and the law of your jurisdiction.  There is certainly nothing wrong with making a passionate, articulate argument, even if it proves to be unpersuasive.  And in weighing these arguments, bear in mind that Mr. LEVITIN is a highly educated and qualified expert in this area of the law and I am merely a fellow pro se litigant lacking in any qualification to give you a legal opinion.


But if you find any merit to my arguments, you might use these as a basis for further research or inquiry, in consultation with a capable attorney competent to give you legal advice!   

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The Equitable One
A brief response to the above is that my PSA does specify New York law as being the governing law.  Section 11.04 of the Pooling and Servicing Agreement, titled "Governing Law; Jurisdiction," states: “This Agreement shall be construed in accordance with the laws of the State of New York and the obligations, rights and remedies of the parties hereunder shall be determined in accordance with such laws.”

I have seen others with similar, and even identical, language. That being said I have seen yet others that do not express such language, or restrictions.

Clearly the research needs to be done in each case and making any assumptions would be a mistake.

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My trust documents also state that a New York common law trust will be formed.  So does this mean that NY trust law is binding on the formation/transfer of assets into the trust?

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William A. Roper, Jr.
The Equitable One said
Clearly the research needs to be done in each case and making any assumptions would be a mistake.

This is exactly RIGHT.  Make no assumptions.  The choice of law provision is either expressly written into the trust indenture and/or other pooling and servicing agreement or it isn't.

Mike said
My trust documents also state that a New York common law trust will be formed.  So does this mean that NY trust law is binding on the formation/transfer of assets into the trust?

As discussed above Professor Adam LEVITIN makes the argument that New York trust law will control the transfer of assets into the trust.  This guy is clearly very bright and certainly is articulate.  And he argues that where the provisions of the trust are very precise that the trust cannot deviate from these in the purchase of the mortgage collateral.

Frankly, I am unpersuaded on several counts and still do not believe that this is going to be a particularly effective argument, but I want to emphasize that I have NOT read or studied ANY New York cases in this area of the law.  I do not believe that there have been ANY cases decided in which the precise question presented has been decided.

Generally speaking, I believe that the core of Mr. LEVITIN's argument is an ultra vires argument.  Ultra vires, which in Latin means "beyond the powers", is the legal concept which recognizes that an entity's power and authority may be and often is limited by the express provision of its chartering documents.

While it is now very common for corporations to be granted broad and even sweeping powers within their corporate charter, usually the articles of incorporation, these can also be expressly and purposefully limited.

For example, a corporation might be chartered for the purposes of operating a railroad or the purpose of operating a state bank.  Very often, the articles of incorporation will include a variety of express authorizations as to the sorts of things that the corporation is authorized to do.  And the articles might even include express prohibitions.

In some instance, the restrictive covenants might reflect a purposeful acknowledgement that the newly chartered entity will not encroach upon some business operated by one of the various chartering investors, partners or principals.

Limitations or restrictions might preclude the enterprise from embarking on certain new lines of business not authorized.  Or the restrictions might limit the business to operation within a particular geographic area or jurisdiction.  Or even without restricting either business line or geography, the restrictions might expressly preclude the enterprise from borrowing money or encumbering certain assets of the corporation.

It is easiest to see and understand the concept of ultra vires within the context of a contractual arrangement which expressly oversteps the defined boundaries of the corporate charter.

For example, suppose that the articles of incorporation expressly prohibit an entity from borrowing money or encumbering the entity's real property by mortgage.  And further suppose that the entity's board of directors or officers were to undertake to borrow money or to mortgage corporate property in express violation of these restrictive covenants within the corporate charter.

In such an instance, the very act of the loan -- the promissory note and mortgage -- might very well be VOID.  The lender should have obtained and inspected the corporate charter to ascertain whether the board or the officers of the corporation had the actual authority to enter into a mortgage loan.

But the concept probably also has its limits.  Suppose, for example, that a corporation had a provision in its charter which expressly prohibited corporate funds from being spent on travel and entertainment expense for officers and directors.  Further suppose that in spite of this prohibition, that the corporation's board was to authorize the corporation to enter into a banking arrangement to include debit cards to be issued to the board members for use with authorized expenses.

Suppose that a corporate employee made a reservation at a hotel for a traveling board member.  Further suppose that a director checked into a hotel and used the corporate debit card for payment.  The bill was paid by the card issuer.  Later, upon audit, inappropriate expenses for travel and entertainment were identified.

Is the arrangement for the night's lodging a VOID arrangement because the hotel failed to inspect the corporation's charter to learn of the limitations?

Can the company demand its money back from the hotel or the card issuer?

While it seems pretty clear that recovery might be had from the board member, it is less clear whether the card issuer or the hotel had a duty of inquiry.  (Most likely, the card issuer had such a duty, but the hotel did not.)

Incidentally, this dicussion is NOT with reference to any particular cases, but rather simply analysis arising out of what I remember from discussion of corporations, partnership and agency law from more than three decades ago in an undergraduate course on the subject.

There is a common sense aspect to this.  One can hardly expect a merchant engaged in small, nominal transactions to make a thorough inspection of the charter as to corporate authority in respect of every transaction.  But happily, cash and carry trade, or payment by a card issuer removes some of the risk.  The small business has the money.

A key defensive protection for the small business person faced with questions about corporate authority is whether the person had the apparent authority to engage in the transaction.  That is there is the actual authority of the entity and there is the apparent authority of those acting on its behalf.


Bringing this back around to mortgages and trusts, it seems to me that Mr. LEVITIN offers to investors in mortgage certificates a very strong argument that the trust provisions set forth rather explicitly what is to be transferred into a trust, how such transfers are to be made and WHEN such transfers are permissible.

But these same ultra vires arguments may be less effective when asserted by a borrower who argues that the loan was transferred into a trust too late.

The hotel which has extended its hospitality to a director engaging in overnight stay has a right to be paid and an expectation of payment.  The investor who relied upon the travel and entertainment provision in making his investment, similarly has a good argument that the officers and directors should be held responsible for the ultra vires expendatures. 

It is a somewhat unreasonable result to suggest that the director should be permitted FREE LODGING at the expense of the hotel due to the corporation's violation of its charter.

So it seems to me that the question of enforcement of the provisions of a trust indenture or a pooling and servicing agreement and the effects of any ultra vires activities is going to turn out to be more of a matter for the trustee and certificateholders than for the mortgage borrowers.


None of this alters the standing argument which is discussed extensively elsewhere within this Forum.


Finally, I would note that while the law of the place where the subject property is located is likely to control the mortgage, deed of trust, security deed or other security instrument, and the trust law specified within a choice of law provision of the trust indenture will control the trust's authority, the commercial law of the place of delivery of the instrument is most likely to control the negotiation of the promissory notes. 

This is because negotiation requires indorsement and delivery and the negotiation is completed by delivery.  For this reason, a line of ancient cases almost everywhere holds that the law of the place of delivery holds.  This used to be New York, when all of the institutional custodians operated out of New York City.  But this is no longer the case.  The physical location of the institutional custodian may control the negotiation.  This can be important as to allonges.

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I have 2 questions pertaining to your last post.

1.  If the pooling and servicing agreement clearly says:

2.11 Permitted Activities of the Trust. The Trust is created for the object and purpose of engaging in the Permitted Activities.


And the document specifically restricts actions that could cause the trust to lose it's REMIC status would you have an argument that they are bound by this?  Transferring an asset into a trust after the closing date would cause a 100% penalty. 


2.  Could a note be transfer ed from the originator to the servicer then the servicer say it was the agent of all the other entities in the chain to the trust so it never left the servicer's possession.  I figured this would be a problem with the endorsement/delivery thing.   Wouldn't this make the servicer just a custodian?

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William A. Roper, Jr.

First, I do NOT want to discourage you from making any compelling and well articulated argument you can craft which helps you to defend against a foreclosure.  Georgetown Law Professor Adam LEVITIN has put forward the argument that New York trust law precludes the untimely transfer of the mortgage collateral by means inconsistent and incompatible with the trust indenture.

I am merely encouraging some caution and MUCH painstaking research!

I think that you are very much on the RIGHT track pointing to provisions such as the one cited.  But read the entire agreement carefully.  There may also be some provisions that contemplate remedial actions to take if there are defects in the closing.  You need not be the one to bring these to the court's attention, but you should at least endeavor to understand them.

I would encourage you to read Mr. LEVITIN's writings, testimony and posts more carefully and to research case law on ultra vires as it applies to NY trusts.  I have little doubt that there is some good case law supporting Mr. LEVITIN's articulated position.  What is less clear is whether this law applies to the circumstance of your case.

Also, you need to be prepared for the possibility that the evidence which seems to point to a belated transfer (the forged assignment) may actually be false evidence, while actual truthful evidence may exist that the collateral was delivered in a timely way.  The plaintiff will very likely let you build an elaborate defense based upon this false evidence and then pull the rug out from under you by claiming actual timely delivery.

It would therefore be a good idea to use discovery to pin down the plaintiff's position, under oath in interrogatory responses or depositions.  And you may want to proceed with some caution in actually pleading the ultra vires argument prematurely.  (No need to take the opposition to school if they haven't yet pled the facts which would give rise to the ultra vires argument.)

The strategy of what to plead and when depends inpart upon the Rules of your jurisdiction and the cases interpretting those Rules. 

In many places, parties are to be accorded much latitude to amend their pleadings when justice so requires.  So if you failed to initially plead the ultra vires argument and evidence in support of this argument and allegation emerged through discovery, then the court might be required under the Rules to allow you to amend your pleadings.

You also might be able to plead alternatively or to plead more generally and then to elaborate later.  Again, what is both possible and advisable depends upon the Rules of your jurisdiction and even the temperment of your judge.

You really need to ask an experienced trial lawyer qualified under the laws of your state for guidance in these matters.


Your question about the delivery of the promissory note from the originating Lender to the mortgage investor and the possibility that the servicer might claim to have held the note on the behalf of others is an interesting one and a question which shows that you are thinking sharply about these dynamics.

I think that any inquiry would find that the intermediate transfers of the collateral to a bankruptcy remote subsidiary of the Lender (the "Plan Sponsor") or the Bankruptcy remote subsidiary of the investment banking concern (the "Depositor") is going to be rather instantaneous and that there may not be any separate servicing agreement in respect of the loans as to the Plan Sponsor and Depositor.

Moreover, this actually is somewhat contrary to the actual path of the promissory note.

Most likely, the promissory note is delivered within about 24 to 72 hours to the institutional custodian of the warehousing lender.  Only upon the sale of the loan pursuant to the PSA will the warehousing lender authorize the release of the collateral.

Whether as a factual matter, the warehousing lender's institutional custodian actually delivers the promissory notes and these are then passed froom the Lender ("A") to the Plan Sponsor ("B") to the Depositor "C" to the Trustee ("D"), which Trustee then gives the negotiable instruments to the institutional custodian, or whether what is transferred is some custodial receipt representing custody of these negotiable instruments in unclear.  But in my view arguing that the transfer took place in respect of the maintenance of the collateral by the Lender ("A") also acting as servicer is pretty sketchy.

The U.S. Bankruptcy Court's holding in the recent In Re Kemp case would seem to me to reflect that courts are unlikely to buy delivery if there was no delivery whatsoever.

Bear in mind that BOA is now asserting that the testimony given by Linda DIMARTINI that the note was never delivered was FALSE.  Unlike many others who see the In Re Kemp case as standing for the proposition that the collateral was never delivered, I have a very different view.  I believe that this case shows that BOA is perfectly willing to fly a witness from the West Coast to authoritatively give false testimony under oath, which I call perjury

I think that Mr. KEMP will be getting a FREE HOUSE, but NOT because of the failure to deliver the promissory note.  I think he gets a free house because BOA once again engaged in perjury and possibly evidence fabrication in another Federal case.


There is another lesson here for foreclosure defendants.  In my experience, if you make a strong defensive case and press the plaintiff through good discovery, that the plaintiff is going to make one or more mistakes.  These mistakes may emerge in surprising and otherwise unexpected ways.  You then need to exploit these mistakes.

I have seen some really great chess players who play consistently well and make few mistakes who can win a game even absent some grand overarching strategy.  Sometimes it is enough to play well, avoid making mistakes or blunders, force the other side a little, and to merely capitalize on the mistakes as they emerge.

In Kemp, the debtor could hardly have imagined that BOA would fly a witness from the West Coast who might give perjured testimony that is so injurious to the bank's relationship with mortgage investors that the bank repudiates her testimony.  To a certain extent, it is the power of the news media and, in particular, the Internet which makes this sort of perjury (or the evidence fabrication in In Re Hill) such a dangerous strategy!

Put on a good defense and mount some aggressive discovery.  Yo umay be very surprised that the foreclosure mill attorneys may LIE, if only to keep in practice!
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William A. Roper, Jr.
Unfortunately, I have been having some access problems with the regular Lexis interface and have been unable to look up any recent cases on ultra vires.

A fellow pro se litigant recently shared with me a digital copy of Black's Law Dictionary, 2nd edition (1910) which contains this insight into ultra vires:

Ultra vires. A term used to express the action
of a corporation which is beyond the powers
conferred upon it by its charter, or the
statutes under which iz was instituted. 13 Am.
Law Rev. 632. ''Ultra vires" is also sometimes
applied to an act which, though within the
powers of a corporation, is not binding on it
because the consent or agreement of the corporation
has not been given in the manner required
by its constitution.  Thus, where a company
delegates certain powers to its directors,
all acts done by the directors beyond the scope
of those powers are ultra vires, and not binding
on the company, unless it subsequently ratifies
them. Sweet. And see Miners' Ditch Co. v.
, 37 Cal. 578, 99 Am. Dec. 80;
Minnesota Thresher Mfg. Co. v. Langdon, 44
Minn. 37, 46 N. W. 312; State v. Morris & E.
R. Co
., 23 N. J. Law, 360; Central Transp.
Co. v. Pullman's Palace Car Co
., 139 U. S. 24,
11 Sup. Ct 478, 35 L. Ed. 55; Latimer v.
Bard (C. O)
76 Fed. 543; Edwards County v.
(Tex. Civ. App.) 33 S. W. 585.

Blacks Law Dictionary, 2nd ed. (1910) pp. 1182,3.

Also defined in this edition is the antonym:

intra vires.  An act is said to be
intra vires ("within the power") of a person
or corporation when it is within the scope of
his or its powers or authority.  It is the opposite
of ultra vires, (q. v.) Pittsburgh, etc.,
R. Co. v. Dodd
, 115 Ky. 176, 72 S. W. 827.

Blacks Law Dictionary, 2nd ed. (1910) p. 653.


Once again, this information is furnished to inform your own inquiry.  You may want to check the more recent editions of Blacks.  Most importantly, check for the latest authoritative cases which relate to the jurisdiction where the mortgage trust in your case was created.


I will post the citations to a couple of cases when I locate these through Lexis.

If others run across useful cases on this topic, you are encouraged to share!
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in my humble opinion this thread is very much worth the read!
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All of Mr. Roper's posts are just exceptional!  If one carefully reads leading national decisions favorable to borrowers, almost every valid winning argument was made here at the Forum first by Mr. Roper.  Those who have followed his suggested strategies are mostly still in their homes.  Those employing the vacuous and questionable strategies suggested by trolls and swindlers are simply posting about "might have beens" and "wish I hads".
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I am adding a link to this related thread by Mr. Roper:

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