JPMorgan Chase Bank, National Ass'n v. SFR Investments Pool 1, LLCAnnotate this Case
The Supreme Court reversed the district court's order granting summary judgment in favor of Defendant in this foreclosure action, holding that the loan servicer timely commenced the action after the foreclosure sale and sufficiently demonstrated that a regulated entity under the Federal Housing Finance Agency's (FHFA) conservatorship owned the loan.
Defendant purchased property at a foreclosure sale. Plaintiff JPMorgan Chase Bank filed a complaint seeking a declaration that the first deed of trust survived the sale and for quiet title. Plaintiff offered evidence that it was servicing the loan on behalf of Freddie Mac, which had previously been placed into an FHFA conservatorship and that the first deed of trust therefore survived under the Federal Foreclosure Bar. Applying a three-year limitations period, the district court entered summary judgment for Defendant, concluding that the foreclosure sale extinguished the deed of trust. The Supreme Court reversed, holding (1) the claims underlying the action are best described as sounding in contract for purposes of the House and Economic Recovery Act statute of limitations, which provides for a six-year statute of limitations; and (2) the Federal Foreclosure Bar prevented the foreclosure sale from extinguishing gate first deed of trust, and therefore, Defendant took the property subject to that deed of trust.