News & Analysis as of

Foreclosure Sales

Weintraub Tobin

Tenant’s Overlooked Risk: Landlord Default

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In the balance of power between landlords and tenants, the risk of default is usually higher for the tenant. While many landlords have accrued wealth and invested in low-risk assets, many tenants are embarking on a new...more

Bradley Arant Boult Cummings LLP

HUD Mortgagee Letter 2026-03 – Bridging the Gap Between Total Debt and CAFMV in the CWCOT Bidding Context

The U.S. Department of Housing and Urban Development (HUD) recently took concrete steps toward addressing industry concerns and uncertainty related to the Claims Without Conveyance of Title (CWCOT) foreclosure bidding...more

White and Williams LLP

Court Denies Injunction in Battle of Titans of New York Real Estate and Allows UCC Sale of Pledged Equity Interests to Proceed

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On January 27, 2026, Justice Andrea Masley, of the Supreme Court of the State of New York, County of New York: Commercial Division Part 48, issued her Decision + Order on Motion, vacating her prior temporary restraining order...more

Falcon Rappaport & Berkman LLP

When the Automatic Stay Is Not Automatic: Bankruptcy Court Upholds Foreclosure Sale Under 11 U.S.C. § 109(g)

In a recent decision from the United States Bankruptcy Court for the Eastern District of New York, In re Frederica West (January 7, 2026; 24-44469), Bankruptcy Judge Elizabeth S. Stong clarified the limits of the automatic...more

Perkins Coie

Foreclosure Does Not Eliminate Density Bonus Obligations: Court of Appeal Upholds Enforceability of Affordable Housing Agreements

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In Rodriguez v. City of Los Angeles, 116 Cal.App.5th 488 (2025), the Second District Court of Appeal held that a recorded density bonus agreement requiring long-term affordable housing survives a foreclosure sale. The court’s...more

Freiberger Haber LLP

The First Department Holds, as a matter of First Impression, that a Party’s Attendance at a Mandatory Settlement Conference...

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This BLOG has previously addressed the issue of a defendant’s appearance in an action – both formal and informal. In that regard, we have noted that it makes sense that a “plaintiff appears in an action merely by bringing...more

Carlton Fields

Real Property, Title Insurance, & Financial Services Update: Week Ending November 21, 2025

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Our Real Property, Title Insurance, & Financial Services Update offers a weekly overview of notable court decisions impacting property rights, title issues, the banking industry, and related litigation. Each edition...more

Nelson Mullins Riley & Scarborough LLP

The U.S. Supreme Court is (Again) Interested in . . . Tax Sales?

County tax sales of real property are rarely a topic of conversation for the average American homeowner.  In the twentieth century, the United States Supreme Court was no different, having only addressed substantive issues...more

Jones Day

New York Bankruptcy Court Adopts "Realistic Possibility" Standard for Free and Clear Sales Under 11 U.S.C § 363(f)(5)

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Section 363(f)(5) of the Bankruptcy Code allows a bankruptcy trustee to sell estate property free and clear of any competing interest in the property (such as a lien or other security interest) if the interest holder "could...more

Ballard Spahr LLP

HUD Modifies Exclusive REO Listing Period and Eliminates Exclusive Sales Period

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Recently, the U.S. Department of Housing and Urban Development (HUD) issued Mortgagee Letter 2025-13 to revise the exclusive listing period for certain parties in connection with HUD real estate owned (REO) properties, and...more

Snell & Wilmer

Recently Enacted California Assembly Bill 2424 and Its Impact on Non-Judicial Foreclosure Procedures

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The California legislature recently passed Assembly Bill 2424, which, as more fully explained below, will have a significant and imminent impact on the nonjudicial foreclosure process of residential real estate. Existing...more

Womble Bond Dickinson

Conducting Efficient and Successful Commercial Foreclosure Sales in Georgia: The Process and Considerations for Lenders

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As a non-judicial foreclosure state, it is often thought of as being “easy” to foreclose in Georgia. However, the foreclosure process requires more than running an advertisement for four weeks and conducting the sale on the...more

Nelson Mullins Riley & Scarborough LLP

Reacting to Tyler v. Hennepin County: Michigan Addresses Retroactivity of Legislative Fix

In a recent case, the Michigan Supreme Court issued an opinion in Schafer v. Kent County, No. 164975, addressing the critical issue of surplus equity stemming from a tax foreclosure within the context of the state...more

Miller Canfield

Michigan Property Owners Entitled to Surplus Value When Foreclosed Property Transferred to Land Bank, Court of Appeals Rules

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Miller Canfield previously reported on Rafaeli, LLC v Oakland County (Rafaeli), in which the Michigan Supreme Court held that counties are not allowed to retain sale proceeds that exceed the taxes owed on a foreclosure...more

Harris Beach Murtha

U.S. Supreme Court Limits Municipalities from Retaining Excess Value in Tax Foreclosures

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On May 25, 2023, the United States Supreme Court, in Tyler v. Hennepin County, ruled it is unconstitutional for municipalities to unilaterally retain the surplus monies generated from tax lien foreclosure sales. More...more

Miller Starr Regalia

A New Class Of Redemptioners: The Enhanced Position Of Tenants, Prospective Owner Occupants, And Nonprofit Or Governmental...

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The borrower has no post-sale redemption right in California’s nonjudicial foreclosure process. This redemption bar has long been justified as a trade-off for the lender’s post-sale deficiency bar under Civ. Proc. Code, §...more

Rosenberg Martin Greenberg LLP

I Submitted the Highest Bid at the Auction. Did I Buy the Property or Not?

Following the onset of the COVID-19 pandemic, many jurisdictions put moratoria in place prohibiting foreclosure sales. However, most moratoria have expired and foreclosure sales, conducted at public auction, are ramping up as...more

Morrison & Foerster LLP

Recent Second Circuit Decision Holds that Conducting a Foreclosure Sale upon a Property After a Tenant Files for Bankruptcy...

In New York, it is a standard practice to name all tenants residing in a building when foreclosing upon the property. That is because section 1311 of the New York Real Property Actions and Proceedings Law (“RPAPL”) states...more

Kaufman & Canoles

Title Insurance Client Alert – Fourth Circuit Rejects Borrower’s Breach of Fiduciary Duty Claim Against Deed of Trust Trustee....

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Recently, a unanimous panel of the United States Circuit Court for the Fourth Circuit issued an unpublished opinion shooting down a borrower’s claim that the substitute trustee of his deed of trust breached its fiduciary...more

Cadwalader, Wickersham & Taft LLP

The ESG Factor, January 2022 - One of These Things Is Not Like the Other: New York State Court Upholds Commercial Reasonableness...

On November 10, 2021, the owner of the State Street Financial Center in Boston, Massachusetts defaulted on its debt, consisting of a mortgage loan in the amount of $535,000,000 and three mezzanine loans in the aggregate...more

Miller Canfield

Michigan Court of Appeals Holds That Development Agreement Obligations are Extinguished in Tax Foreclosure

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The Michigan Court of Appeals recently held that assessments on a property under a development agreement between a city and the property's former owner did not survive a tax foreclosure and therefore were not liens against...more

Bowditch & Dewey

A Victory For Lenders – The Massachusetts Supreme Judicial Court Holds That a Pre-foreclosure Notice of Default and Right to Cure...

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The Massachusetts Supreme Judicial Court’s recent decision in Thompson v. JPMorgan Chase Bank, N.A., — N.E.3d —-, 2020 WL 7238390, at *4 (1st Cir. Dec. 9, 2020) represents a substantial victory for the financial services...more

Greenberg Glusker LLP

Lessons for Health, Beauty & Wellness Companies [Part 3]: When to Consider Acquiring a Distressed Company

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In this short, three-part video series, Greenberg Glusker Partners Andrew Apfelberg and Brian Davidoff discuss important financial considerations for health, beauty and wellness companies in the wake of a pandemic. Part three...more

Seyfarth Shaw LLP

Courts Continue to Analyze How COVID-19 Orders Affect Private Party Rights

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Three recent decisions demonstrate how the legal landscape continues rapidly to change and evolve in response to COVID-19. These decisions highlight certain developing uncertainties in the law, including the impact of...more

Troutman Pepper Locke

NY Court Blocks Mezzanine Lender’s UCC Foreclosure Sale in Light of COVID-19 Pandemic

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On June 23, the New York County Supreme Court issued a rare preliminary injunction temporarily halting a mezzanine lender’s UCC foreclosure sale of the Mark Hotel in New York City because the procedures for the foreclosure...more

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