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Commercial Litigation Landlord Tenant Law

Second Circuit Narrows Borrower’s Ability to Pursue Class Damages In Federal Court for Failure to Timely Record Mortgage Satisfactions

The decision in Maddox v. Bank of N.Y. Mellon Trust certainly affords safeguards to lenders and mortgagees in that Maddox now narrows a borrower’s ability to pursue class damages in federal court for lenders and services for failure to timely record mortgage satisfactions.


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If at first you don’t succeed, try again. In Maddox v. Bank of N.Y. Mellon Trust Co., N.A., the United States Court of Appeals for the Second Circuit got it right by vacating its prior order in light of the Supreme Court’s TransUnion LLC v. Ramirez, 141 S. Ct. 2190 (2021), decision. 2021 U.S. App. LEXIS 34056 (2d Cir. Nov. 17, 2021).

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