InMaddox v. Bank of N.Y. Mellon Trust Co., N.A., 997 F.3d 436, the Second Circuit recently held that individuals have Article III standing to seek statutory damages for
Federal Class Action Available for Delay In Recording Mortgage Satisfaction
Because the Second Circuit held that a bare violation of New York's Mortgage-Satisfaction-Recording Statutes without a demonstration of actual injury conferred federal jurisdiction, a mortgagor now has the ability to bring a class action in federal court.

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