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Navigating Foreclosure in States with 'One Action Rules

by Joshua M. Hayes
Shumaker, Loop & Kendrick, LLP - Charlotte Office

May 27, 2014

Previously published on May 1, 2014

Late last year, the New York Supreme Court decided 172 Madison (NY) LLC v. NMP Grp., LLC, in which it examined New York’s one-action rule, a complex and often misunderstood rule that can have huge implications for lenders providing or servicing loans secured by real property in jurisdictions that have such rules, such as New York and California. This article provides background on the one-action rule and other anti-deficiency statutes before analyzing the holding in 172 Madison. It then examines the rule’s application in other jurisdictions, and provides some practical tips for lenders that operate in one-action rule States.


The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.

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