Daily News related to the Foreclosure Crisis

The biggest unpunished heist in human history - Max Keiser

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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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04/29/22

CFPB Bites of the Month - April Top 10 JDSupra

CFPB Bites of the Month - April Top 10
We thank you for reading our Top 10 and listening to our CFPB Bites of the Month webinars over the past two years. In this month's article, we share some of our top "bites" for the prior month covered during the April 20 webinar. So, what happened at the CFPB in the past month?

04/29/22

How Bias Works Against Justice in Foreclosure Litigation Living Lies

How Bias Works Against Justice in Foreclosure Litigation
If one takes a neutral view there is an inescapable and undeniable conclusion: millions of homes have been forced to sale, depriving the owners of property and money, and causing untold damage to families and careers without the court knowing to a reasonable degree of certainty that the loan account even exists.

04/28/22

Interpleader Might Be Useful in Revealing the Absence of Any Unpaid Loan Account Living Lies

Interpleader Might Be Useful in Revealing the Absence of Any Unpaid Loan Account
One of my constant comment contributors recently informed me and others that she was trying a new tack. She writes “My attorneys are making a demand that any refi money be placed with the Court and that the judge decides who he wants to pay.”

04/27/22

Global Megabanks Are Tanking – The Same Ones the Fed Bailed Out in 2019 Wall Street On Parade

Global Megabanks Are Tanking – The Same Ones the Fed Bailed Out in 2019
As long-term readers of Wall Street On Parade know well, we have regularly warned that the failure of Congress to meaningfully reform Wall Street by restoring the Glass-Steagall Act poses a national security threat to our nation in times of crisis. Instead of meaningful reform, Congress has stood by and watched the Fed bail out the global banks repeatedly since 2008 – either with direct loans or by keeping interest rates artificially low (“administered rates”) or through trillions of dollars in asset purchases from the banks (what the Fed prefers to call Quantitative Easing).

04/27/22

Living Truth: CFPB Moving Against FINTECH Companies Living Lies

Living Truth: CFPB Moving Against FINTECH Companies
It’s time to give a thumbs up to the agency that has up till now befuddled homeowners. The absence of regulation of nonbank FINTECH companies has been a giant loophole through which wealth was converted from homeowners to investment banks. I am pleasantly surprised by an announcement from the CFPB that will start monitoring and investigating these companies like Black Knight, Fiserv and CoreLogic — i.e., the REAL servicers who are involved in the collection of money that nobody is entitled to receive.

04/26/22

When the homeowners loses in the trial court what are the options? Living Lies

When the homeowners loses in the trial court what are the options?
Foreclosure litigation is a very special type of case. Normal rules of limitation and basic requirements of proof have been softened in favor of giving lawyers the opportunity of saying they represent a Bank that is the trustee of a trust. Those lawyers don’t need to assert that the trust owns any underlying obligation owed by the homeowner to the named Bank as trustee. It is all implied. And they never are required to show proof of authority to represent the bank. In fact, they have no contact with the bank.

04/25/22

Cleveland leads the nation in new foreclosure filings, Ohio third among states News5 Cleveland

Cleveland leads the nation in new foreclosure filings, Ohio third among states
CLEVELAND — New numbers out show the nation’s foreclosure rate is on the rise with Ohio one of the states with the sharpest increase and Cleveland number one among all major cities.

04/25/22

Texas Homeowner Harriet Nicholson is On the Road Seeking Justice Laws In NY

Texas Homeowner Harriet Nicholson is On the Road Seeking Justice
Nicholson knows Nationstar is plotting to steal her home because they know the judicial system is rigged against homeowners in Texas.
Nicholson v. The Bank of New York Mellon
(1:22-cv-03177)
District Court, S.D. New York
APR 19, 2022 | REPUBLISHED BY LINY : APR 25, 2022

04/25/22

JURISDICTIONAL CHALLENGES MUST NOT BE AIMED AT THE MERITS OF THE CLAIM Living Lies

JURISDICTIONAL CHALLENGES MUST NOT BE AIMED AT THE MERITS OF THE CLAIM
“Jurisdiction” is a term used to define whether or not the court has any authority to hear the case. Filing a bogus claim DOES invoke the jurisdiction of the court as long as it complies with the basic rules of court. Just because you call it a jurisdictional challenge doesn’t make it a jurisdictional challenge. The jurisdiction of the court is based upon several factors,

04/22/22

Supreme Court Supports Equitable Tolling Extend Legal Deadlines NCLC

Supreme Court Supports Equitable Tolling Extend Legal Deadlines
A unanimous Supreme Court on April 21, 2022, issued an important ruling applicable when consumer practitioners have difficulty meeting a limitations period found in consumer legislation. In Boechler, P.C. v. Commissioner of Internal Revenue, 2022 WL 1177496 (U.S. April 21, 2022), the Court ruled

04/22/22

2021 update - Olympic Gold Medalist Cindy Brown Wins Hearing and Stunning Court Victory on Constitutional Right to Due Process and Dignity for Self-Represented Litigants Facing Vexatious Litigant Motions Sherry Hernandez

2021 update - Olympic Gold Medalist Cindy Brown Wins Hearing and Stunning Court Victory on Constitutional Right to Due Process and Dignity for Self-Represented Litigants Facing Vexatious Litigant Motions
School Lawyer and civil rights attorney Raye Mitchell delivers research and support in Cindy Brown vs. The Bank of New York Mellon in defending vexatious litigant claims by bank attorneys-The Ryan Firm APC.

04/22/22

So you think you’re in default, eh? Clouded Titles

So you think you’re in default, eh?
The author of this post will try to keep things simple without passing judgment. There is no doubt here that we are collectively living in troubled times. The rash of foreclosures continues now that the eviction moratoriums have been lifted for the most part. Those who did not undertake a loan modification or request a forbearance (that was actually granted) are probably feeling the sting of communication by the mortgage loan servicers in their mailing out of late notices on unpaid and delinquent mortgage loans. According to the terms of the mortgage or deed of trust (depending on which “state” you’re in), there is a specific section on Default. Understand that it’s the mortgage loan servicer’s obligation to collect the mortgage loan debt and route payments to the “lender”, no matter WHO that lender might be. The problem with defaults, loan modifications and the like is that so many of the loans out there today are securitized through the MERS® System. Since the MERS® System was taken over by the same company that owns the New York Stock Exchange, the information coming out of this entity is scarce to non-existent. Generally, if you miss a payment, the servicer is going to notify you by certified mail. You may have to sign for the letter. The biggest mistake that homeowners make is ignoring these letters, when in fact, this could be the very start of a long, drawn-out process where you can obtain a lot of useful and vital information that your attorney could use in a foreclosure defense posture, without having to pay gobs in legal fees. What is a QWR? That process is called a Qualified Written Request (QWR) under RESPA (the Real Estate Settlement Procedures Act) § 6. You can easily research this section of the law and discover that RESPA allows you to send a QWR to the servicer’s bona fide QWR address and ask the servicer to send you specific information, which is discussed below.

04/22/22

DannLaw Covid 19 Update 16–and hopefully our last Dann Law

DannLaw Covid 19 Update 16–and hopefully our last
The End of Covid Forbearance is here. Time to rework your loan. DannLaw founder Marc DannMortgage forbearance and other programs made available to homeowners during the COVID-19 pandemic are about to end. That means millions of homeowners are or will soon be pursuing loan modifications or other work out options with their lenders.

04/22/22

How to use your knowledge of securitization to win foreclosure and quiet title cases Living Lies

How to use your knowledge of securitization to win foreclosure and quiet title cases
In an effort to show the relevancy of securitization in the collection businesses established with each new transaction with homeowners, I have had some discussions about the usefulness of knowing who has access to funds paid by homeowners and who gets paid any money as a creditor of the homeowner.

04/21/22

Foreclosure Activity at New High Since the Pandemic Began Realtor Magazine

Biden Has Nominated a Man from the Sandy Weill/Robert Rubin/Tim Geithner School of Wall Street Hubris to Head Regulation at the Fed
Foreclosure starts and bank repossessions are at their highest numbers in the last two years. Most pandemic-initiated moratoriums have lifted by now and lenders are starting to resume foreclosures. Still, foreclosure activity remains well below historical levels. The number of properties with a foreclosure filing during the first quarter of 2022 climbed 39% compared to the previous quarter. Foreclosure filings are up much higher—132%—compared to a year ago, according to ATTOM Data Solutions’ Q1 2022 U.S. Foreclosure Market Report.

04/20/22

Biden Has Nominated a Man from the Sandy Weill/Robert Rubin/Tim Geithner School of Wall Street Hubris to Head Regulation at the Fed Wall Street On Parade

Biden Has Nominated a Man from the Sandy Weill/Robert Rubin/Tim Geithner School of Wall Street Hubris to Head Regulation at the Fed
In addition to being a law professor at the University of Michigan, Michael Barr also holds the title as the “Joan and Sanford Weill Dean of Public Policy at the University of Michigan’s Gerald R. Ford School of Public Policy.” The Ford School sits in a building called the Joan and Sanford Weill Hall, which was given that name as the result of a $5 million donation from the Weills. To anyone who hasn’t been in a coma since the Wall Street crash of 2008 –

04/20/22

Homeowner Beliefs and Fears Drive Losses in Court Living Lies

Homeowner Beliefs and Fears Drive Losses in Court
There is no “YES”. There are many people who get angry with me for ascribing some blame to the homeowners themselves for the toxic economic environment and the judicial environment resulting in the victimization of homeowners.

04/19/22

MERS and the problem of false agency Living Lies

MERS and the problem of false agency
Since the beginning of this century, The initial transaction with homeowners was the product of multiple layers of paperwork, most of which were neither identified nor accessed by consumers or their professional advisers. * Here is the deal:

04/18/22

A mortgage giant crunched 47 years of housing data. Here's what it found Inman

A mortgage giant crunched 47 years of housing data. Here's what it found
The new Fannie Mae Home Price Index aims to capture a broader picture of the housing market. What it found was the fastest annual pace of home price growth in nearly half a century

04/18/22

Notices To and From Servicer Might Mean Nothing at All Living Lies

Notices To and From Servicer Might Mean Nothing at All
In homeowner finance, ALL claims start with notices from third parties with whom the homeowner has previously had no communication. My suggestion is that homeowners start challenging those letters, statements, and notices as soon as they arrive. Such challenges make “tracks in the sand” for later use in litigation.

04/17/22

MAAPL for Housing Justice—$60K for Grace’s 60th! MAAPL.org

MAAPL for Housing Justice—$60K for Grace’s 60th!

Hi Everyone, Grace Ross here. I’m honored that the Mass Alliance Against Predatory Lending is celebrating my 60th birthday with a $60,000 fund raiser for the amazing work to bring justice to… everyone, really, in the US, given our country’s historically high rate of foreclosures.
Ever since I was a kid, my birthday candle wish was always about everyone having a home. That seemed just a reasonable and necessary thing — every human being should have a safe place to rest their head. Giving now will help reach that dream.
So, here I am today — working with MAAPL’s amazing, diverse leadership. If we succeed in this fight for justice, we’ll accomplish something never done before in US history: return vast stolen wealth and land. This foreclosure crisis — the worst since the one that fed the American Revolution— was started by the lenders. For the first time in history, after the Civil Rights Movement’s fights winning and ending the use of law to deny people of color the ability to own their home. Redlining and what was known as reverse redlining were outlawed. (This was where the few people of color who could get mortgages were given mortgages that were what is now called “doomed to foreclose”) And, for the first time, women got out from under needing their husband’s credit for a mortgage.
Those streams of folks came into being able to get a mortgage under the law to own their home only to find themselves targeted by the same reverse redlining practices. Those practices were sufficiently successful by the end of the 1990s that the lending industry started applying them to white folks – primarily working class white men – as well.
Foreclosure has affected every walk of life. We can now prove bank practices are not only civilly illegal, but usually criminally too. After 13 years of fighting, MAAPL is poised to turn this tide. How? With enough organizing and legal staff to blow away the prejudiced lie that people ”bought too much house” — most mortgages were targeted refinances, loans guaranteed to lose the home.
Join our online Celebration & Virtual Fundraiser with music, stories of hope and hard earned wins, plus the plan to bring the wealth home. #Black/Brown Wealth Matters
How? With your help. MAAPL needs $60,000 to hire organizing staff. Will you donate to make history with us?
Our movement also is looking for $360,000 in investment money for my birthday —a whole different way to contribute— for huge, multi-party, legal cases. Be in touch with me, Grace and I can connect you with this transformative and handsome investment opportunity.
And thanks for the honor, everyone.

04/16/22

State fund helps homeowners Record Eagle

State fund helps homeowners
TRAVERSE CITY — Hundreds of Michigan homeowners have already applied for grants to cover financial hardships brought on by the pandemic, and Traverse City has become the latest partner to the Michigan Homeowners Hardship Assistance Fund.

04/15/22

Preserving the Property Preservation Space DS News

Preserving the Property Preservation Space
Kerry Medel is Client Relationship Manager for Brookstone Management LLC, a nationwide firm specializing in preserving and maintaining vacant, pre-foreclosure, and REO assets.

04/15/22

Don’t wait until the end: Interlocutory appeals succeed where the issues are narrow Living Lies

Don’t wait until the end: Interlocutory appeals succeed where the issues are narrow
Aggressive litigation means basically that the lawyer or pro se litigant uses every tool in the box to force the opposition onto its heels or out of the courtroom. Each state has its own rules and laws governing interlocutory appeals.

04/14/22

Calif. AG encourages COVID-impacted reverse mortgage borrowers to seek relief Reverse Mortgage Daily

Calif. AG encourages COVID-impacted reverse mortgage borrowers to seek relief
Rob Bonta, the attorney general for the state of California, issued an alert this week to encourage more of the state’s residents to avail themselves of the California Mortgage Relief Program that includes assistance for forward and reverse mortgage borrowers who have been financially impacted by the economic effects of the COVID-19 coronavirus pandemic.

04/14/22

Hawaii Court of Appeals - Bank of N.Y. Mellon v. Colton, 146 Haw. 577 (2020) -- More evidence of judicial bias in US state courts? Scott Stafne

Hawaii Court of Appeals - Bank of N.Y. Mellon v. Colton, 146 Haw. 577 (2020) -- More evidence of judicial bias in US state courts?
OPINION OF THE COURT BY WADSWORTH, J. Defendant/Counterclaim Plaintiff-Appellant Mary Lee Colton (Colton) appeals from the judgment entered on February 10, 2017, by the Circuit Court of the Third Circuit (Circuit Court)1Link to the text of the note pursuant to Hawai'i Rules of Civil Procedure (HRCP) Rule 54(b) (February 10, 2017 ...read more

04/14/22

Capital Markets, eClosing, Borrower Intelligence, Automation Products; Fannie and Freddie Relentless Changes Mortgage News Daily

Capital Markets, eClosing, Borrower Intelligence, Automation Products; Fannie and Freddie Relentless Changes
It’s Thursday. What should we talk about today? Elon Musk’s bid for Twitter? How about the jump in adjustable-rate locks as evidenced by the MBA’s figures? (Are your LOs well-versed in them?) Their share of applications last week was at 7.4 percent, which was the highest share since June 2019. How about this unique measure of wage inflation?

04/13/22

Take Charge America Offers Arizona Residents Free Rent & Mortgage Counseling, Guidance in Qualifying for $25,000 in Mortgage Assistance Business Wire

Take Charge America Offers Arizona Residents Free Rent & Mortgage Counseling, Guidance in Qualifying for $25,000 in Mortgage Assistance
-Arizonans facing foreclosure, eviction or struggling to pay their mortgage or rent can receive one-on-one housing counseling services from nonprofit agency Take Charge America, including the possibility of qualifying for up to $25,000 in mortgage assistance through the state’s Homeowner Assistance Fund.

04/13/22

Candidates for Office and Lawyers for Consumers Are Missing the Brass Ring Living Lies

Candidates for Office and Lawyers for Consumers Are Missing the Brass Ring
We need to elect candidates who run on an anti-bank platform. That means getting to them when they are just sorting out whether they will run or when they first start running. Any message that ties current day-to-day problems for citizens to the banks will resonate.r

04/11/22

Law Practices at Foreclosure Mills Could Lead to Prosecution Living Lies

Law Practices at Foreclosure Mills Could Lead to Prosecution
I doubt if it comes as any real surprise to the many law firms that quickly organized to file claims against consumers — especially homeowners. But the money was just too good to turn it down. In an article in the New York Law Journal by Jason Grant, he reveals that Attorney General Letitia James sued a law firm for

04/11/22

Fannie Mae announces title insurance shake up Housing Wire

Fannie Mae announces title insurance shake up
In a selling guide announcement released last week, Fannie Mae announced that it would be accepting written opinion letters from an attorney in lieu of a title insurance policy “in limited circumstances.”

04/08/22

CFPB’s appeal to Ocwen suit off to a rough start Housing Wire

CFPB’s appeal to Ocwen suit off to a rough start
U.S. Court of Appeals ruled that most complaints against servicer are barred because of 2014 consent order The Consumer Financial Protection Bureau’s attempt to revive a mortgage servicing misconduct lawsuit against Ocwen Financial Corp. is in choppy waters.

04/08/22

40-yr, Jumbo, Co-op, Audit, Credit, Homebuyer Tools; Freddie and Fannie Program News Mortgage News Daily

40-yr, Jumbo, Co-op, Audit, Credit, Homebuyer Tools; Freddie and Fannie Program News
The risk-free 2-year Treasury began 2022 yielding .73 and is now at 2.52 percent! Does your company offer 2-1 buydown loans? Do your LOs even know what a 2-1 buydown loan is? (If they don’t, bring them up to speed internally or through a program like XINNIX.) Things are changing.

04/07/22

RON is here to stay – Here’s what you need to know Housing Wire

RON is here to stay – Here’s what you need to know
Remote Online Notarization is a hot topic in the real estate title industry for good reason. An ALTA Vendor Survey showed that RON transactions increased by 547% from 2019 to 2020. While the pandemic thrust RON into the mainstream of the industry,

04/07/22

Compliance priorities on the horizon for 2022 ABA

Compliance priorities on the horizon for 2022
Predicting the new year’s compliance developments is easier in some years than others. In some years, a large piece of legislation (such as Dodd-Frank) must be implemented by regulators and the year (or in Dodd-Frank’s case, several years) will be dominated by new proposals and regulations to sort out.

04/07/22

Fannie and Freddie issue guidance implementing foreclosure hold for HAF applicants Consumer Finance Monitor

Fannie and Freddie issue guidance implementing foreclosure hold for HAF applicants
As previously reported, the Federal Housing Finance Agency announced that Fannie Mae and Freddie Mac will require servicers to suspend foreclosure activities for up to 60 days if the servicer has been notified that a borrower has applied for assistance from the Treasury Department’s Homeowner Assistance Fund (HAF).

04/07/22

How Evidence Works for and Against the Consumer/Homeowner Living Lies

How Evidence Works for and Against the Consumer/Homeowner
It is easy to get lost in the weeds. Don’t make up your own words or definitions because your definitions have no relevance to your case. Do hold the accusing side to their words and to the legally accepted definitions of those words as contained in statutes and cases.

04/06/22

DannLaw, Zimmerman Law Offices file class action against Wells Fargo, say bank discriminated against Black borrowers The Dann Law Firm

DannLaw, Zimmerman Law Offices file class action against Wells Fargo, say bank discriminated against Black borrowers
-- Claiming that Wells Fargo has engaged in a “…pervasive pattern and practice of placing Black Americans at a disadvantage in comparison to White Americans with respect to their applications for mortgage loans,” attorneys from DannLaw and the Zimmerman Law Offices filed a class action lawsuit against the giant bank in the United States District Court for the Eastern District of New York on Tuesday, April 6, 2022.

04/06/22

Why it is important that it is not PennyMac or Ocwen etc. (It’s usually Fiserv) Living Lies

Why it is important that it is not PennyMac or Ocwen etc. (It’s usually Fiserv)
The biggest problem for nearly everyone viewing these pages is that besides the legal and financial jargon, the concepts are difficult to understand. So I keep getting questions and comments that basically amount to “So what” What difference does it make whether the named servicer is performing those functions or it is someone else?”

04/05/22

Why the UCC Matters in Foreclosure Cases Living Lies

Why the UCC Matters in Foreclosure Cases
The problem as illustrated by many scholarly articles and articles on this blog is that courts are given to treat plaintiffs and claimants as holders in due course without anyone asking them to do so.

04/04/22

After reaching historic lows, the foreclosure pipeline is starting to fill Inman

After reaching historic lows, the foreclosure pipeline is starting to fill
Although the numbers remain below historical levels, ‘it’s not going to be a surprise when we see the foreclosure numbers starting to rise,’ according to Daren Blomquist of Auction.com

04/04/22

Helping borrowers hold mortgage servicers accountable CFPB

Helping borrowers hold mortgage servicers accountable
On Monday, the Consumer Financial Protection Bureau (CFPB) filed a friend-of-the-court (“amicus”) brief in McCoy v. Wells Fargo Bank, N.A., a case in which two mortgage borrowers sued their loan servicer for refusing to answer their questions about their loans.

04/04/22

Mortgage Payment to Income Ratio Getting Into Pre-Meltdown Territory Mortgage News Daily

Mortgage Payment to Income Ratio Getting Into Pre-Meltdown Territory
Black Knight's latest Mortgage Monitor report was released this morning and it provided more timely insight on home price appreciation than last week's home price indices (HPIs) from FHFA and S&P Case-Shiller. The Mortgage Monitor's price data covers February whereas the other HPIs were limited to January.

04/03/22

The Morrises are now up at the Mass. SJC: to be HEARD, this MONDAY, 040422 at about 10:30am (time is not exact). MAAPL.org

The Morrises are now up at the Mass. SJC: to be HEARD, this MONDAY, 040422 at about 10:30am (time is not exact).
HSBC Bank USA v. MorrisSJC-13191 View Docket
Webcast Home Page

Summary: Mortgage Foreclosure-- This is a challenge to an eviction action after a mortgage foreclosure claiming that the underlying loan was predatory.

This is our first chance to show the Massachusetts Supreme Judicial Court that it needs to stand up for the people of Massachusetts, especially the people of color and communities with a higher percentage of people of color who were targeted for the illegal, predatory, and, in fact, “prohibited” discriminatory loans that the industry across the board has rampantly engaged in.

We have all been horrified by what the Massachusetts Supreme Judicial Court did to Alton King and said was ok to be done to everybody similarly situated. That is, anybody who is “post foreclosure” and needs fees waived to be able to fight for their rights in our courts can be denied. (Although we are fighting that in the lower courts and getting there… )

We have an opportunity to show the SJC that we are watching and that they need to do the right thing. Please put THIS Monday on your calendar.

We are still checking if observers can be in the Courtroom itself BUT that would be the most impressive. If you can’t make it OR we find out we can’t witness in person PLS plan to watch - we will figure out a way to let the court know how many people are watching!

Webcast Home Page
They need to know how many people are watching and how many people are going to be paying attention to whether they choose the people of Massachusetts over the mega-banks or not and whether they start the process of reparations and healing that we have a Constitutional right to.
Much love, Grace
MAAPL.org

04/03/22

UNCOVERED: A Greenwood judge auctioned foreclosed properties. His wife and children bought dozens. Index-Journal

UNCOVERED: A Greenwood judge auctioned foreclosed properties. His wife and children bought dozens.
Once a month, investors across the state turn up to the local seat of government looking for a bargain on real estate. On a Monday morning in Greenwood, they form a loose circle beside the big windows in the courthouse’s mid-century lobby, awaiting a chance to buy properties away from owners who can’t afford them anymore.

04/01/22

You Don’t Need to Call a Forensic Investigator as an Expert: He or she can be called as a fact witness thus avoiding any requirements to qualify an expert. Living Lies

You Don’t Need to Call a Forensic Investigator as an Expert: He or she can be called as a fact witness thus avoiding any requirements to qualify an expert.
I keep getting messages from homeowners who are furious with the corrupt system of the courts because they tried to call a witness to testify as an expert and they failed. Calling an expert means you must fulfill numerous requirements. One of them, the threshold question, is whether an expert is even needed.

04/01/22

NY Modifies Foreclosure Provisions JDSupra

NY Modifies Foreclosure Provisions
Effective immediately, New York S.B. 7698 has amended foreclosure requirements for residential mortgages by adding clarification that any complaint served in a proceeding initiated on a residential mortgage covering a one to four family dwelling must contain the affirmative allegation that at the time the proceeding is commenced (for loans governed by section six-l or six-m of the banking law) the plaintiff has complied with section six-l or six-m of the banking law. The bill further clarified that it shall be a defense to an action to foreclose a mortgage if a lender violates any provision of section six-l or six-m of the banking law or section thirteen hundred four of the Real Property Actions & Proceedings Law, for loans governed by these provisions.

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