The recently reported three (3) panel decision in Vukman v. Beneficial Consumer Discount Company brings into play the validity of using the Uniform Act 91 Notice that was adopted on June 5, 1999 by the Pennsylvania Housing Finance Agency (“PHFA”) and was in effect until September 8, 2008. The Court held that the judgment and subsequent sheriff’s sale were null and void because, in the Court’s view, the Act 91 Notice did not inform the mortgagor of a right to have a face-to-face meeting with the lender/mortgagee.
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