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Promissory Estoppel Foreclosure

Burr & Forman

Florida Appellate Court Rejects Defense of Oral Loan Modification Defense on Statute of Frauds Grounds

Burr & Forman on

In Cowen Loan Servicing, LLC v. Jean Marie Delvar, 4D14-763, 2015 WL 8347300 (Fla. 4th DCA Dec. 9, 2015) the borrower alleged that he had been offered a loan modification and accepted and relied on that offer by making loan...more

Goodwin

N.D. Illinois: Bank’s HAMP Procedures Weren’t Unfair or Deceptive

Goodwin on

A U.S. District Judge in the Northern District of Illinois recently granted summary judgment in favor of defendant PNC Bank on a borrower’s promissory estoppel and Illinois Consumer Fraud Act (ICFA) claims in connection with...more

Sheppard Mullin Richter & Hampton LLP

No Change Of Position, No Estoppel

Under California Law, a party seeking to defeat the statute of frauds based on promissory estoppel must allege an actual change in position. In Jones v. Wachovia Bank, 230 Cal.App.4th 935 (2014), the California Court of...more

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