In this post, I explain why it matters that banksters produce the note before they are allowed to foreclose. One of the tricks played on the courts by banksters is the “lost note affidavit”. Here’s my translation from legalese: Your honor, my client really really really owns this note, it just can’t find it right now. Or the dog ate it. Or its kid brother threw it in the trash and its mom dumped garbage on it and you just can’t read it but here’s a copy, really (cue Seth and Amy, no link because nbc.com loads really slowly). Lawyers tell these stories to the courts because the Uniform Commercial Code has a provision that allows them to foreclose even when they can’t find the right pieces of paper: UCC § 3-309.
§ 3-309. ENFORCEMENT OF LOST, DESTROYED, OR STOLEN INSTRUMENT.
(a) A person not in possession of an instrument is entitled to enforce the instrument if:
(1) the person seeking to enforce the instrument
(A) was entitled to enforce it the instrument when loss of possession occurred, or
(B) has directly or indirectly acquired ownership of the instrument from a person who was entitled to enforce the instrument when loss of possession occurred;
(2) the loss of possession was not the result of a transfer by the person or a lawful seizure; and
(3) the person cannot reasonably obtain possession of the instrument because the instrument was destroyed, its whereabouts cannot be determined, or it is in the wrongful possession of an unknown person or a person that cannot be found or is not amenable to service of process.
(b) A person seeking enforcement of an instrument under subsection (a) must prove the terms of the instrument and the person’s right to enforce the instrument. If that proof is made, Section 3-308 applies to the case as if the person seeking enforcement had produced the instrument. The court may not enter judgment in favor of the person seeking enforcement unless it finds that the person required to pay the instrument is adequately protected against loss that might occur by reason of a claim by another person to enforce the instrument. Adequate protection may be provided by any reasonable means.
Subsection (a) explains which note losers are entitled to prove that they have enforceable rights despite their incompetence at basic record keeping. It includes people who buy non-existent pieces of paper from others, a group which should be laughed out of court as examples of financial Darwinian selection.
Subsection (b) says that the note loser has to prove the exact terms of the note, which ought not be a problem. A note loser trying to foreclose should be able to come up with a copy of the note. There are several cases where the note loser couldn’t even find a copy of the instrument, and they were not allowed to proceed.
The key point is that the note loser has to prove that it has the right to enforce the instrument. It isn’t enough to say “I have the right to enforce the instrument.” There has to be proof of that right. The copy might show the entire chain of transfers, concluding with the note loser, which would constitute proof. In the case of real estate mortgages in securitizations, most likely it won’t. Instead, it may have the first endorsement, and all the others are in blank, and it may be that there is no first endorsement. That will be a real problem where the mortgage originator is out of business.
That means proof by means of documents, which in turn means that there is going to be expensive and time-consuming discovery, requests for production of documents, and then depositions. In those cases, settling makes more sense than litigating.
There is an Oklahoma bankruptcy case on a credit card obligation. The note loser found an assignment in bulk of credit card obligations, but could not produce the attachment showing that the specific debt was transferred. In cases like that, courts hold that there was no proof of right to enforce and they do not permit the note loser to proceed.
Paper matters, even if it only means lengthy and expensive proof.



14 Comments




How do you think the banks have been able to work around the issue with their LNAs and back-dated assignments during the past two weeks? What new fabricated documents would satisfy the judges this time?
I doubt that the foreclosures ever stopped. I think they continue unabated and we were treated to a PR event. The head rocket docket judge in Sarasota County is pushing the same propaganda as Shaun Donovan:
I have noticed that PR is the only thing that seems to matter anymore. Certainly more than “rule of law.” Pffft.
Thanks for following up masaccio with further explanation of some of the law involved in this mess.
I don’t believe the Uniform Commercial Code applies to real estate transactions. Are you certain that it does?
Randy Kelton has done some ground-breaking work on getting these fraudsters. He did a really eye-opening interview on Alex Jones’ show yesterday (10/20, hours 3 and 4) regarding stopping these rapacious bastards in their tracks using pro se litigating.
His website for those who are seeking help with mortgage related problems is here.
Good point.
U.C.C. section 9-104(j) excludes from the coverage of Article 9 an interest in real estate.
Legal reasoning varies by state -
mortgage as a conveyance of the title, which can be defeated on payment of the debt; or
a lien, entitling the borrower to all the rights of ownership, as long as the terms of the mortgage are observed, or
in California one uses a deed of trust to a trustee who holds title for the lender, and in
Louisiana we have two types of judicial foreclosure proceedings in Louisiana, executory and ordinary process, with interesting clause and witness requirements.
Most states ignore the old common law idea that if the borrower failed to pay the debt in full at the appointed time, the borrower suffered a complete loss of title, replacing that with Courts of equity, now having authority to decide cases on the basis of moral obligation, fairness, or justice, as opposed to the law courts, which were bound to decide strictly according to the common law. But in some states the lender may be granted a deficiency judgment for the balance of the debt after the foreclosue sale against the debtor, with the right to resort to other assets or income for its collection.
And then there are those subdivision or condominium development mortgages that cover a large tract of land where there are blanket mortgages. A blanket mortgage makes possible the sale of individual lots or units, with the proceeds applied to the mortgage, and partial release of the mortgage recorded to clear the title for that lot or unit.
And there are Construction mortgages that may follow state construction lien law, and possibly open-end mortgages that make possible additional advances of money from the lender without the necessity of a new mortgage.
Since Lenders regularly assign mortgages to other investors, we have Assignments with recourse are that are guarantees by the one who assigns the mortgage that that party will collect the debt; those without recourse do not contain such guarantees.
Not exactly a simple topic.
I should note I am not an expert on anything dealing with mortgages – I was involved in the internation sale of a pool of mortgages but my role was the different taxation recordings that made for a reason for the transaction to go forward – and I depended on some very good lawyers as to all documents. My take away was that “its complicated”.
I should also note that masaccio’s main point – that documents count and if you can’t find a document you have a lot of legal work ahead of you in order to replace the lost item – is spot on.
The UCC doesn’t apply to real estate transactions. It does, however, govern the promissory note, if any, issued in the borrowing. That note is a negotiable instrument, governed by the UCC.
As papau points out, the provisions of Article 9 do not apply to real estate mortgages.
This just came through on Rortybomb, under the title
Quoted from the opinion:
The case was decided and the opinion written in 2007!
Please reference the statement by the Uniform Commercial Code committee, Judges Bufford and Ayers revisions of the UCC 3 for bankruptcy. The demand for proof of a holder in due course is much more simple. It is a much higher bar for proof of standing. April 3, 2009.
http://www.scribd.com/doc/27860264/Ucc-Judge-Buford-Ayers-Abi-20090212-113015
SUMMARY
The cases cited illustrate enormous problems in the loan servicing industry. These problems arise in the context of securitization and illustrate the difficulty of determining the name of the holder, the assignee of the mortgage, and the parties with both the legal right under Article 3 and the standing under the Constitution to enforce notes, whether in state court or federal court.
Interestingly, with the exception of Judge Bufford and a few other judges, there has been less than adequate focus upon the UCC title issues. The next round of cases may and should focus upon the title to debt instrument. The person seeking to enforce the note must show that:
• It is the holder of this note original by transfer, with all necessary rounds;
• It had possession of the note before it was lost;
• If it can show that title to the note runs to it, but the original is lost or destroyed, the holder must be prepared to post a bond;
• If the person seeking to enforce is an agent, it must show its agency status and that its principal is the holder of the note (and meets the above requirements).
Then, and only then, do the issues of evidence of debt and default and assignment of mortgage rights become relevant.
I have gathered two years of research and writing and put it all under one cover.
I call it my OPUS: Housing fraud A-Z, 2002-Presebt
There was collusion from the beginning.
Most alarming is the fact, proven in the article, is that many homes were underwater the minute the buyer signed the note. Proof of widespread appraisal fraud by lenders included.
The whole story, all the players. the choreographed plan set forth before the launch of the Housing Boom, etc.
Enjoy! And please share with others. Again, this my Housing/Mortgage/Foreclosure OPUS, First Draft.
http://www.dailykos.com/story/2010/10/21/912375/-Housing-Fraud-Opus:-From-A-Z,-Collusion-by-All
Unfortunately, masaccio, you have not even uncovered the real legislative crime. I give you Colorado Senate Bill 02-161 as Exhibit A. Prior to the enactment of SB 02-161, everyone needed a “wet ink” note and deed of trust to initiate a foreclosure proceeding with the Public Trustee. If you did not have the original note with the original assignments, you had to prove that it was lost or destroyed, your right to foreclose and post a bond of one and one-half times the original obligation. This bill allowed banks and certain other institutions an exemption from these requirements because, I guess, they are so much more trustworthy than the rest of us. No original note is required anymore, just a certification that the bank has the original note and is the proper holder.
This is the bill that made the CMO derivative market possible – at least for property in Colorado. It is also the bill that has invited the current foreclosure fraud. I am willing to wager that if you looked, you would find that similar bills were passed in other states about the same time. This was right after Congress passed and Clinton signed Gramm’s commodity modernization act.
The really sad thing is that SB 02-161 was sponsored by a Democrat. It passed the Colorado senate and house unanimously. Not a single Democrat questioned it.
thank you again masaccio -
Karl Denninger highlights a case with a “supplemental affidavit” in his post this morning