Thursday, May 3, 2018

FYI: DC App Ct Holds HOA May Not Foreclose Subject to First Deed of Trust

The District of Columbia Court of Appeals recently held that a condominium association acting on its six-month super-priority lien for unpaid condominium assessments pursuant to § 42-1903.13(a)(2) of the District of Columbia Condominium Act (the "DC Condo Act") may not conduct its foreclosure sale subject to a first deed of trust lien, even if the terms of sale stated that the condo unit would be sold subject to first deed of trust.

 

A copy of the opinion is available at:  Link to Opinion

 

Borrower obtained a loan to finance his purchase of a condominium unit (the "Unit") secured by a deed of trust recorded in the land records.  The loan and deed of trust were later assigned to plaintiff mortgagee ("Mortgagee"). Borrower subsequently defaulted on his mortgage payments and condominium assessments.

 

The Borrower's condominium association (the "Association") sought to foreclose on the Unit pursuant to D.C. Code § 42-1903.13(a)(2), which entitles condominium associations to a super-priority lien for the most recent six months of unpaid assessments.  Throughout 2011 to 2014, the Association scheduled several foreclosure sales, but the sales were cancelled after Mortgagee paid the delinquent assessments to preserve its lien on the Unit. 

 

In 2014, Borrower defaulted again on his assessments and the Association scheduled a foreclosure sale.  The Association provided notice to Borrower and Mortgagee.  Notably, the Association publicly advertised the sale and that advertisement stated that the Unit would be sold pursuant to D.C. Code § 42-1903.13(a)(2) and "subject to a deed of trust for approximately $589,750."

 

At the sale, the Unit was sold to third-party purchaser defendant ("Defendant").  The accounting showed that the Association deducted $5,195.28 for almost six months of unpaid assessments, as well of other foreclosure costs and fees, out of the $17,000 purchase price of the Unit paid by Defendant.   Mortgagee attempted to pay the Assessments to stop the sale, but the Association returned the check because it was not received until the day after the sale.  The Association later recorded a deed which included a provision stating: "The hereinafter described property is sold subject to a deed of trust."

 

Mortgagee filed a complaint for judicial foreclosure against Borrower and later joined Defendant. Both Mortgagee and Defendant moved for summary judgment.  Defendant alleged that she purchased the Unit at a foreclosure sale, free and clear of Mortgagee's lien pursuant to D.C. Code § 42-1903.13(a)(2) and the appellate court's decision in Chase Plaza Condominium Ass'n v. JPMorgan Chase Bank, N.A., 98 A.3d 166, 172 (D.C. 2014). 

 

The trial court granted the Mortgagee's motion and denied plaintiff's motion.  The trial court acknowledged that law was unclear regarding the effect of the Association's foreclosure sale, pursuant to its super-priority lien, on a mortgagee's first-priority mortgage lien at the time of the sale at issue.  The trial court held that the Unit was clearly sold subject to the first mortgage lien and it would be "an inequitable windfall and contrary to the parties' expectations to permit [Defendant] to disavow [Mortgagee's] mortgage . . . and would impose an enormous foreclosure deficiency on [Borrower] if [Borrower's] purchase is not subject to [Mortgagee's] lien, as was contemplated at the foreclosure sale.  Defendant appealed.

 

On appeal, the issue was whether Mortgagee's first mortgage lien was extinguished by foreclosure of the Association's super-priority lien under D.C. Code § 42-1903.13(a)(2) despite the advertisement and sale of the Unit subject to the first mortgage lien.

 

Defendant contended that she purchased the Unit at the foreclosure sale free and clear of Mortgagee's first mortgage lien because the anti-waiver provision of the DC Condo Act precluded the Association from enforcing its super-priority lien subject to Mortgagee's first deed of trust.  Mortgagee argued that trial court correctly granted summary judgment based on equitable and other grounds.

 

The Court first addressed its prior ruling in Chase Plaza Condominium Ass'n v. JPMorgan Chase Bank, N.A., noting that it had similar facts to the present case.  There, the Court addressed for the first time the proper interpretation of an association's super-priority lien for unpaid assessments under D.C. Code § 42-1903.13(a)(2) and the impact of a foreclosure on a lender's first mortgage. 

 

As you may recall, under the DC Condo Act, liens for unpaid assessments are split into two liens of differing priority.  An association is granted a higher priority lien over a first mortgage lien for the most recent six months of unpaid condominium assessments.  The Act also grants the association a lien for any remaining unpaid liens beyond the most recent six-month period, but at a lower priority than the first mortgage lien.

 

In Chase Plaza Condominium Ass'n v. JPMorgan Chase Bank, N.A., the association's foreclosure notice specified that the foreclosure sale of the unit would not be subject to a first mortgage. The unit was purchased by a third-party at the foreclosure sale and lender filed suit seeking the rescission of the sale.  The trial court granted summary judgment in favor of the mortgagee on basis that the purchaser could not lawfully extinguish the first deed of trust. Thus, the foreclosure sale was voided because "the unit had not been sold subject to the first deed of trust."

 

The Court reversed the trial court's decision noting the well settled principle of foreclosure law that "liens with lower priority are extinguished if a valid foreclosure sale yields proceeds insufficient to satisfy a higher-priority lien." The Court noted that the plain language of the DC Condo Act did not evince an intent to deviate from this general principle.

 

The Court explained that the legislative history of the DC Condo Act indicated the intent to give associations maximum flexibility in collecting unpaid assessments.  Further, the Court noted that the official comments to the Uniform Common Interest Ownership Act and the Uniform Condominium Act (collectively, "Uniform Acts") suggest that it was understood by lenders that an association's super-priority lien would extinguish a first mortgage and lenders would take steps to avoid this result by requiring payment of assessments into escrow or paying the assessments themselves to avoid foreclosure. 

 

§ 42-1901.07 of the DC Condo Act provides that "except as expressly provided by this chapter, a provision of this chapter may not be varied by agreement and any right conferred by this chapter may not be waived."  Thus, the Court rejected Mortgagee's argument that Association did not enforce its super-priority lien because terms of sale stated that the Unit would be sold subject to first deed of trust.

 

The Court held that the DC Condo Act precluded the Association from exercising its super-priority lien while also preserving the full amount of the Mortgagee's unpaid lien as this would effectively constitute a waiver.  Thus, the Court found that the Association enforced its super-priority lien at the sale because it collected only on the most recent six months of unpaid assessments.  Because the proceeds were insufficient to cover the first mortgage lien, the first mortgage lien was therefore foreclosed out.

 

Notably, the DC Appellate Court did not address whether the sale should be set aside for equitable reasons because the sole count in Mortgagee's complaint was for judicial foreclosure.

 

The Court found it important to address and reject Mortgagee's additional claims. Notably, the Court found that Defendant was not equitably estopped from claiming that the first deed of trust was extinguished at the sale.  The Court noted that Mortgagee did not reasonably rely on the advertised terms of the foreclosure sale to protect its interest because it attempted to pay the delinquent assessments but failed to do so on time.  Further, the Court noted, Mortgagee did not move to vacate the sale after the Unit for the relatively low price even though it knew the state of the law on super-priority liens was in flux.  The Court also noted that equitable relief is not available when granting such relief would contravene the express provision of a statute, i.e. the anti-waiver provision of the DC Condo Act.

 

The DC Appellate Court also rejected Mortgagee's claim that a secured party lender and association may agree to subordinate the super-priority lien based on a report ("Report") created by the Joint Editorial Board for Uniform Real Property Acts ("JEB").  In the Report, the JEB presented a scenario where an association may agree with a lender to deliver title clear of its super-priority lien after foreclosure of a first mortgage lien if the proceeds of the sale are first distributed to the association to cover the lien.  The Court explained that the super-priority lien would still exist after the foreclosure. Thus, the Court held, this scenario does not suggest subordination of the super-priority lien, but rather, reinforces its true priority status.

 

Further, the DC Appellate Court rejected Mortgagee's claim that a super-priority lien may not be enforce through a non-judicial foreclosure because the Act contemplates non-judicial enforcement of liens "unless the power of sale procedures are specifically and expressly prohibited by the condominium instruments." Citing D.C. Code § 42-1903.13(c)(1).  Here, the Association's bylaws explicitly authorized non-judicial foreclosure.

 

Last, the Court rejected Mortgagee's claim that the Association's foreclosure sale could not have been conducted pursuant to its super-priority lien due to the Association's prior attempts to foreclose.  Mortgagee relied on comments in the Report advising that an association cannot extend a six-month super-priority lien by filing successive actions every six months.

 

However, the DC Appellate Court found that the comments only apply where a foreclosure action is already pending at the time an association attempts to file an additional foreclosure action. If a foreclosure action is already pending, foreclosure by an association is not necessary and would represent an attempt to extend lien priority beyond six months entitled to priority status.

 

Accordingly, the DC Appellate Court reversed the trial court's order granting summary judgment to Mortgagee and remanded for further proceedings.

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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Tuesday, May 1, 2018

FYI: Ill App Ct (1st Dist) Rules HOA Lien Extinguished by Payment 1 Year After Foreclosure Sale

The Appellate Court of Illinois, First District recently held that a foreclosing mortgagee's payment of post-foreclosure sale assessments nearly a year after the sale date confirmed the extinguishment of a condominium association's lien for pre-sale assessments created under the Illinois Condominium Property Act (the "Act").

 

In so ruling, the First District found that the plain language of the Act did not place any "temporal requirement on the payment of post-purchase assessments in order for the payment to confirm the extinguishment of any lien created under subsection 9(g)(1) of the Act[.]"

 

A copy of the opinion is available at:  Link to Opinion

 

The defendant mortgagee foreclosed on its mortgage and purchased the condominium unit (the "Unit") at the foreclosure sale on November 13, 2015.  The trial court in the foreclosure action confirmed that sale in January 2016.

 

On August 30, 2016, defendant mortgagee requested verification of the amount of assessments due and owing from the condominium association ("plaintiff association").  On September 1, 2016, plaintiff association provided a ledger reflecting $5,411.31 in unpaid assessments accruing from November 13, 2015 through September 1, 2016.

 

The mortgagee sent a check to the plaintiff association on September 13, 2016 for the unpaid post-sale assessments.  However, on November 30, 2016, plaintiff association issued a Notice and Demand for possession of the Unit to defendant mortgagee demanding $17,810.35 for unpaid assessments that accrued prior to the foreclosure sale.  Thereafter, plaintiff association filed suit.

 

In response, defendant mortgagee filed a motion seeking dismissal of the complaint, or in the alternative, summary judgment.  Defendant mortgagee argued that its payment of $5,411.31 in post-sale assessments confirmed extinguishment of plaintiff association's lien pursuant to section 9(g)(3) of the Act ("Section 9(g)(3)"). 

 

Plaintiff association filed a cross-motion for summary judgment arguing, inter alia, that defendant mortgagee did not comply with section 9(g)(3)'s requirements by failing to pay monthly assessments for the Unit in the month following the sale, and therefore, the lien created under section 9(g)(1) of the Act ("Section 9(g)(1)") was not confirmed extinguished by the payment in September 2016.

 

The trial court granted defendant mortgagee's motion for summary judgment and denied plaintiff association's cross-motion for summary judgment.  Plaintiff association appealed.

 

On appeal, the only issued argued by plaintiff association was whether, pursuant to section 9(g)(3), defendant mortgagee's $5,411.21 payment on September 13, 2016 confirmed the extinguishment of plaintiff association's lien for pre-sale assessments created under Section 9(g)(1).

 

Plaintiff association argued that section 9(g)(3) required defendant mortgagee to begin remitting payment for post-sale assessments immediately in the month following the sale to confirm extinguishment of the Section 9(g)(1) lien.  Thus, plaintiff association argued, defendant mortgagee's payment in September 2016 did not extinguish the lien for pre-sale assessments.

 

However, the Appellate Court rejected plaintiff association's argument that section 9(g)(3) provides for a rigid deadline of the month following the foreclosure sale to commence remitting post-sale assessments.

 

The Court noted that "it is clear that a foreclosure buyer's duty to pay monthly assessments begins on 'the first day of the month after the date of the judicial foreclosure sale.' But on the face of the statute, section 9(g)(3) does not contain any time limit for confirming the extinguishment of an association's lien." See Country Club Estates Condominium Ass 'n v. Bayview Loan Servicing LLC, 2017 IL App (1st) 162459, ¶ 14 (internal citations omitted).

 

The Appellate Court also cited heavily from the Illinois Supreme Court decision in 1010 Lake Shore Ass'n v. Deutsche Bank National Trust Co., 2015 IL 118372 ("1010 Lake Shore").  In 1010 Lake Shore, the Illinois Supreme Court explained that "[t]he first sentence of section 9(g)(3) plainly requires a foreclosure sale purchaser to pay common expense assessments beginning in the month following the foreclosure sale." 

 

However, the Appellate Court did not interpret this phrase to mean that a purchaser at a foreclosure sale must commence remitting post-sale assessments in the month following the sale.  Rather, the Court explained that "first sentence of section 9(g)(3) merely fixes the date when the purchaser's liability for assessments begins." 

 

Thus, the Appellate Court held that defendant mortgagee was not required to immediately remit post-sale assessment payments in the month following the foreclosure sale to confirm the extinguishment of plaintiff association's lien for pre-sale assessments.

 

It is important to note that the Illinois Supreme Court in 1010 Lake Shore advised that "[t]he second sentence [in section 9(g)(3)] provides an incentive for prompt payment of those [post-sale] assessments, stating '[s]uch payment confirms the extinguishment of any lien created' under subsection 9(g)(1) by the prior unit owner's failure to pay assessments." 

 

Thus, relying on 1010 Lake Shore, plaintiff association argued alternatively that defendant mortgagee did not "promptly" pay post-sale assessments for the Unit, and therefore, the September 2016 payment did not confirm extinguishment of the Section 9(g)(1) lien. 

 

However, in rejecting plaintiff association's argument, the Appellate Court noted that the Illinois Supreme Court in 1010 Lake Shore "did not hold that prompt payment is a condition precedent to confirmation of the extinguishment of any lien created under subsection 9(g)(1) of the Act."  Rather, the Appellate Court explained that the payment of post-sale assessments is an additional step necessary to confirm extinguishment of the Section 9(g)(1) lien.  However, prior to the confirmation of extinguishment by the post-sale payment, the Section 9(g)(1) lien is enforceable. The "incentive for prompt payment" is taking the additional step required for extinguishment of the lien before the lien is enforced.

 

The Appellate Court explained that the ruling in 1010 Lake Shore supported the conclusion that "payment of post-purchase assessments, whenever made, is the step necessary to confirm the extinguishment of any lien created under section 9(g)(1)[.]"  Indeed, the Court noted that the Illinois Supreme Court "never qualified its analysis by stating that, before the payment of post-purchase assessments could act to confirm the extinguishment of any lien created under subsection 9(g)(1) of the Act, the payment must be made promptly following the purchase of the condominium at a foreclosure sale."

 

The Appellate Court further explained that the supreme court in 1010 Lake Shore "found no ambiguity in the provisions of the Act; rather, it found the language to be plain it its requirements."  Thus, the Court found that "the legislature did not place any temporal requirement on the payment of post-purchase assessments in order for the payment to confirm the extinguishment of any lien created under subsection 9(g)(1) of the Act; nor do we believe that the supreme court in 1010 Lake Shore found promptness of payment to be an implicit requirement in the statute."

 

In light of the above, the Appellate Court found that defendant mortgagee's payment on September 13, 2016 satisfied all of the post-sale assessments that had accrued since the date of the sale.  Therefore, the Court held that defendant mortgagee's payment confirmed extinguishment of any lien held by plaintiff association for unpaid pre-sale assessments under Section 9(g)(1).

 

Accordingly, the Appellate Court affirmed the trial court's order granting summary judgment in favor of defendant mortgage and denying plaintiff association's cross-motion for summary judgment.

 

 

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia  |   Illinois   |   Indiana   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC   |   Wisconsin

 

 

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Sunday, April 29, 2018

FYI: 4th Cir Holds HPA Does Not Require LPMI Disclosures If LPMI Not Required at Closing

The U.S. Court of Appeals for the Fourth Circuit recently concluded that lender-paid mortgage insurance ("LPMI") under the federal Homeowners Protection Act, 12 U.S.C. § 4901 et seq, ("HPA"), are only required if LPMI is a condition of the borrower obtaining the loan. 

 

In affirming the trial court's dismissal of the borrower's claims, the Fourth Circuit dissected the specific language of the provision in the HPA addressing disclosures related to mortgage insurance, 12 U.S.C. § 4905.  Specifically, the Fourth Circuit determined that the disclosures are only required if LPMI is a condition of the loan at the time of closing. 

 

In this case, the lender did not condition the loans to the plaintiff borrowers on obtaining LPMI at the time of closing.  Instead, the lender began purchasing LPMI weeks to several months after the loans closed in order to make the loans more marketable on the secondary market.  Because LPMI was not, at the time of closing, a condition of borrowers obtaining the loans, the Fourth Circuit affirmed that the notice requirements under the HPA were not triggered.

 

A copy of the opinion is available at:  Link to Opinion

 

The plaintiff borrowers were members of a putative class who had obtained thirty-year, fixed-rate mortgage loans between June 2007 and December 2008.  The loans were all obtained through a "No Fee Mortgage Plus" program offered by the lender. The No Fee Mortgage Plus loans were advertised as charging no fees in connection with closing and requiring no private mortgage insurance.

 

Shortly after launching the program nationwide in 2007, the lender began obtaining LPMI on certain pools of closed and funded loans that had been offered through the program. According to the lender, this decision was made to increase liquidity during the financial crisis that began to affect the housing market that year. The lender believed purchasing LPMI gave it the option to sell the loans on the secondary market. LPMI was eventually purchased on each of the Plaintiffs' loans. For those loans which eventually received LPMI, the timeline for the purchase of LPMI ranged from one or two weeks after closing to several months after closing.

 

While looking to refinance their loan, the named Plaintiffs discovered that the lender had purchased LPMI on their loan.  This putative class action ensued, in which Plaintiffs brought various state causes of action for fraud and consumer protection violations, and a claim under the HPA that the lender did not provide certain mortgage insurance disclosures required by the HPA.

 

The trial court granted summary judgment to the lender on the federal claims. The Plaintiffs moved for reconsideration based on a declaration of a former employee of the lender. In response, the trial court affirmed its initial decision on the federal claims, and granted summary judgment to the lender on the state claims, and issued final judgment.

 

Plaintiffs appealed on the grounds that the trial court erred in its application of the HPA, abused its discretion in managing discovery, and wrongly granted summary judgment on the state law claims.

 

As you may recall, under the HPA, "not later than the date on which a loan commitment is made for [a] residential mortgage transaction, the prospective mortgagee shall provide to the prospective mortgagor a written notice." See 12 U.S.C. § 4905(c). The required disclosures include "a generic analysis of the differing costs and benefits," including the difference between LPMI and borrower paid mortgage insurance, the fact that LPMI may be tax-deductible, and the fact that LPMI "usually results in a residential mortgage having a higher interest rate than it would in the case of borrower paid mortgage insurance." Id.

 

The disclosures, however, are not required with every mortgage. Under the HPA, the disclosures are only required "[i]n the case of lender paid mortgage insurance that is required in connection with a residential mortgage transaction." Id. It was this provision on which the Fourth Circuit focused its attention, as the Plaintiffs argued that this language makes the disclosures mandatory any time a lender purchases LPMI on a loan, even if LPMI is obtained after closing and is not a condition of closing.

 

The Fourth Circuit broke down the critical provision, phrase by phrase.  "The plain meaning of the key statutory phrase 'required in connection with a residential mortgage transaction' involves conditions at the time a mortgage loan is closed."  The Court continued, "the 'residential mortgage transaction' is the loan's closing, the phrase 'in connection with' conveys the close nexus between satisfaction of the requirement and the loan's closing, and the word 'required' means just that—necessary for the transaction to move forward."

 

The Court rejected Plaintiff's argument that the disclosures were required, regardless of when the LPMI was obtained.

 

The Fourth Circuit also looked at the congressional comments to the HPA, which provided the basic concepts of the HPA. "The HPA-mandated disclosures directly address these [borrowers'] concerns [with mortgage insurance] by highlighting how mortgage insurance might affect a borrower's bottom line so that borrowers 'can assess the benefits and drawbacks of this product.'"

 

The Court then emphasized that the key factor on whether the disclosures were required was whether the LPMI was a condition of the loan at closing.  "That Congress limited the mandatory disclosures to situations in which LPMI is 'required in connection with a residential mortgage transaction' makes clear that Congress did not intend the disclosures as a general education effort. Instead, the disclosures are designed to provide specific information to those most in need of it at precisely the time that it can be most useful."

 

According to the Fourth Circuit, any other interpretation would subject lenders to potential violations of the HPA in situations where the lender obtained LPMI years after the loan closed.  The Court was not willing to read the HPA that broadly and put lenders in the position of providing the disclosures for every loan. 

 

The Court summarized its conclusion: "the language and design of 12 U.S.C. § 4905(c) reveal a single plausible meaning: banks must provide LPMI disclosures only when LPMI is a condition of a loan at closing."

 

The Fourth Circuit also rejected Plaintiffs' argument that the lender's post-closing purchase of LPMI affected the interest rate on Plaintiffs' loans.  According to the Court, the evidence demonstrated that purchasing of LPMI after the closing did not adversely affect Plaintiff's loans or any other loans. 

 

Because LPMI was not a condition to Plaintiffs' loans at the time of closing, the Court affirmed the district court's ruling.  The Court also dismissed Plaintiffs' state law claims, as they were preempted by the HPA, which explicitly preempts state laws "relating to . . . any disclosure of information addressed by" the HPA.  12 U.S.C. § 4908(a)(1)

 

Finally, the Fourth Circuit summarily rejected Plaintiffs' argument that additional discovery could have uncovered evidence that the lender always intended to purchase LPMI on the loans and then passed the cost into Plaintiffs' interest rates.  According to the Court, the parties had over fourteen months to conduct discovery, and the lender produced over 88,000 documents.  "Plaintiffs are not entitled to endless discovery to search for evidence for their claims." 

 

Accordingly, the Fourth Circuit affirmed the trial court's dismissal of Plaintiffs' claims against the lender. 

 

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia  |   Illinois   |   Indiana   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC   |   Wisconsin

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


Our updates and webinar presentations are available on the internet, in searchable format, at:

 

Financial Services Law Updates

 

and

 

The Consumer Financial Services Blog

 

and

 

Webinars

 

and

 

California Finance Law Developments