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
Second Circuit Expands Federal Class Actions for Mortgagors
The Second Circuit recently held that a bare violation of mortgage satisfaction recording statutes without a demonstration of actual injury conferred federal jurisdiction, meaning that a mortgagor now has the ability to bring a class action in federal court. Thus, statutes designed to be merely remedial in nature can now be used punitively against lenders and servicers.

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