News & Analysis as of

Fair Debt Collection Practices Act Standing Mortgages

Troutman Pepper Locke

Sixth Circuit Affirms Dismissal of FDCPA Claims for Lack of Standing, But for Lack of a Causal Connection

Troutman Pepper Locke on

In a recent decision, the U.S. Court of Appeals for the Sixth Circuit affirmed the dismissal of federal claims brought by a mortgagee against Trinity Financial Services, LLC (Trinity) under the Fair Debt Collection Practices...more

Hinshaw & Culbertson - Consumer Crossroads

Tips for Loan Servicers on Defending Consumer Claims in Federal Court and Making Successful Article III Standing Challenges

Loan servicers and their counsel are often sued by consumers during contested mortgage foreclosure proceedings. The United States Supreme Court’s opinions in Spokeo, Inc. v. Robins and TransUnion v. Ramirez continue to be an...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending April 23, 2021

Carlton Fields on

Real Property Update - Condo / Attorneys’ Fees: Condominium association that lost on counterclaim against developer was prevailing party on significant issues in litigation by prevailing on developer’s claims and was...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending December 18, 2020

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Real Property Update - Foreclosure / Subrogation: Trial court erred in entering final judgment of foreclosure in favor of subsequent mortgagee where subsequent mortgagee attempted to preserve and assign an otherwise...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending August 14, 2020

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Real Property Update - Foreclosure / Standing: assignee of note was entitled to foreclosure for being in possession of original note indorse in blank, consistent with the copy attached to the complaint - Deutsche Bank...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending July 31 , 2020

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Real Property Update - Foreclosure / Surviving Lien: Lender’s lien on mobile home survived foreclosure sale of property where mobile home was located; mobile home remained personal property outside scope of foreclosure –...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending July 17, 2020

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Financial Services Update- TCPA / Standing / Text Messages: Plaintiff failed to establish standing to bring TCPA claim because plaintiff had not shown he suffered an injury in fact where he received two text messages,...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending May 22, 2020

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Real Property Update - Wrongful Foreclosure: Borrower could not sustain wrongful foreclosure claim against lender where certificate of sale had been vacated and certificate of title was never issued – Jallali v. Christiana...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending April 3, 2020

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Real Property Update - Foreclosure: Where the foreclosure defendant was properly served, and default and default final judgment was entered against said defendant, the defendant can only contest the unliquidated damages...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending March 20, 2020

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Real Property Update - Foreclosure / Surplus: Purchaser of real property per an agreement for deed was not the record owner and could not claim foreclosure sale surplus – Corey v. Neuffer, No. 2D19-1083 (Fla. 2d DCA Mar....more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending March 13, 2020

Carlton Fields on

Real Property Update - Foreclosure / Standing: Holder failed to prove standing to enforce note either at inception or at time of judgment because it failed to prove it had possession of original note and accompanying...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending February 14, 2020

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Real Property Update - Foreclosure / Standing: Where plaintiff was substituted in as a party plaintiff after original note was filed with the court, introduction of original note bearing blank indorsement into evidence at...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending January 17, 2020

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Real Property Update - Condition Precedent / Summary Judgment: Master association was not an owner of the condominium association and lacked standing to defend litigation based upon condominium association’s alleged...more

Carlton Fields

Financial Services Update: Week Ending November 1, 2019

Carlton Fields on

Financial Services Update - FCCPA and FDCPA: The plaintiff did not demonstrate a genuine issue of material fact that medical providers and their attorney violated the FCCPA and FDCPA by conditioning medical services on a...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending October 18, 2019

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Real Property Update - Foreclosure / Statute of Limitations: default notice pursuant to paragraph 22 of subject mortgage may include amounts accrued outside five-year statute of limitations – U.S. Bank, Nat’l Ass’n v....more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending July 19, 2019

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Real Property Update - Foreclosure / Condo Assessments: under section 718.116(1)(a), Florida Statutes, present condo owner is jointly and severally liable with the previous owner for unpaid assessments and related expenses...more

Carlton Fields

Real Property & Financial Services Update: Week Ending June 14, 2019

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Real Property Update - Foreclosure / Business Records / Hearsay: trial court abused its discretion in excluding collection notes into evidence where witness sufficiently laid predicate for admissibility of these records -...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending June 7, 2019

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Real Property Update - Foreclosure / Standing: owner of property subject to mortgage at the time the complaint and lis pendens were filed had standing to dispute legal sufficiency of proof of amount due where owner was...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending April 26, 2019

Carlton Fields on

Real Property Update - • Foreclosure / Reverse Mortgage / Condition Precedent: bank failed to establish that the subject property was not the principal residence of surviving co-borrower under its reverse mortgage, a...more

Carlton Fields

Financial Services & Title Insurance Update: Week Ending March 22, 2019

Carlton Fields on

Financial Services Update - FDCPA / definition of "debt collector": law firm carrying out a nonjudicial foreclosure action not a debt collector because the primary definition of a "debt collector" under sec. 1692a does not...more

Carlton Fields

Real Property & Financial Services Update: Week Ending March 15, 2019

Carlton Fields on

Real Property Update- Deed Restriction / MRTA: Marketable Records Title to Real Property Act extinguished association's restrictions where restrictions were more than thirty years old, predating lot owner's root of title,...more

Carlton Fields

Financial Services & Title Insurance Update: Week Ending March 1, 2019

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Financial Services Update - FDCPA: no liability for a debt collector that provides the name of the hospital, the account number, patient name, date of service, and amount of debt, but who fails to include the word "creditor"...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending January 25, 2019

Carlton Fields on

Real Property Update - Trespass / Temporary Injunction: temporary injunction order premised upon a physical trespass onto property, which did not specify actions that constitute trespass, did not enjoin use of airspace over...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending November 16, 2018

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Real Property Update - Derivative v. Direct Action / Standing: individual member of LLC not entitled to sue title company for breach of fiduciary duty because right to sue belonged to LLC, where LLC suffered the direct...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending November 9, 2018

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Real Property Update - Foreclosure/Attorneys' Fees: where borrower prevailed on argument that dismissal of foreclosure action was required as bank was not entitled to enforce a mortgage contract containing a fee...more

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