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Can the “Produce the Note” Strategy Really Stop Foreclosure?

By
Real Estate Agent with Keller Williams Realty

It's the Internet age, and more and more homeowners are searching the Internet to find out how they can save their home if they’re in foreclosure. One strategy I’ve been asked about several times is the “Produce the Note” strategy. Some articles have been written that have led many homeowners to believe that this strategy is the “silver bullet” to delay or stop foreclosure, or even get your mortgage wiped out completely so you own your house free and clear.

The “Produce the Note” strategy requires the lender to prove it has the actual authority to foreclose, by requiring it to produce the original promissory note. The goal is to make certain that the foreclosing lender is, in fact, the owner of the note. There is only one original promissory note for your mortgage that has your signature on it. This is the document that proves that you owe the debt.

During the lending boom, many mortgages were sold off to other lenders or servicer or sliced up and sold to investors as securitized packages on Wall Street. In the frenzy of turning these over as fast as possible to make the most money, many of the new lenders did not get the proper paperwork to show they own the note and mortgage. This is the key to the strategy—Lenders are foreclosing on homeowners, but don’t have the proper paperwork to prove they have a right to foreclose.

Sounds pretty simple--If they can’t produce the original promissory note, then you don’t really owe the debt, right? In Washington State (and other non-judicial foreclosure states), that’s not necessarily the case.

Judicial Foreclosure vs. Non-Judicial Foreclosure

In a judicial foreclosure state, the bank must sue the borrower and go to court in order to foreclose. The “Produce the Note” request is done as part of the lawsuit. Washington is a non-judicial foreclosure state, meaning that the lender doesn’t have to take you to court in order to foreclose. You can request that the bank produce the original note, but they’re likely to disregard the request completely, leaving you with only one other option--File a lawsuit against the lender and request that they produce the original note. This could become very time consuming if you try to do it yourself, or expensive if you use an attorney. I don’t recommend filing a lawsuit without the help of an attorney. Also, this strategy is more effective when your loan has been sold off on the secondary market. If it hasn’t, then your lender most likely has the original note and can easily produce it.

My Own Experience With Lost Promissory Notes

I have been in situations with my own properties where original promissory note was lost. I've worked with notes from private lenders and seller carry-back notes, and these non-institutional lenders sometimes lose the original note. The seller carrying back a note may scan the original note and Deed of Trust into their computer then discard the originals, not realizing that they were supposed to keep them. When the note is being paid off and the lender cannot produce the original note or Deed of Trust, the escrow company just has them sign and notarize an "Indemnification of Lost Deed of Trust and Original Note". Then everything is fine.


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Authored by David Monroe, Realtor and Pre-Foreclosure and Short Sale Specialist.
Access Seattle area short sale help and foreclosure resources including selling in foreclosure, and 8 Ways to Avoid or Stop Foreclosure.

Copyright (c) 2009 by David Monroe (Home4Investment Team at Keller Williams Seattle Metro West).
Can the "Produce the Note" Strategy Really Stop Foreclosure?

Show All Comments Sort:
Ben de Anda
RE/MAX Cross Country - Corinth, TX

Wow, I have never heard of such a thing.  Thank you for the blog.  I work a bunch of Short Sales here in Texas. Keep up the good work.

 

Oct 06, 2009 07:06 AM
Bill Gillhespy
16 Sunview Blvd - Fort Myers Beach, FL
Fort Myers Beach Realtor, Fort Myers Beach Agent - Homes & Condos

Hi David,  There is a lot of information on this strategy but I'm curious whether or not it has proven effective.

Oct 06, 2009 07:16 AM
David Monroe
Keller Williams Realty - Kirkland, WA
Short Sale Real Estate Agent

TB98629 - I'll address a couple points that you commented on:

1.  You mentioned that courts are not allowing "...ANYTHING as proof of ownership" other than the wet ink original of the note that the borrowers signed.  I agree with that and didn't state anything to the contrary on my original post.  To clarify the last paragraph of my post, the "Indemnification of Lost Deed of Trust and Original Note" is a way for the lender to say, "I'm the owner of the note, but since I can't produce proof, I will indemnify the borrower (compensate the borrower for damage or loss sustained and secure against future anticipated loss or liability) if someone else produces proof that they're the rightful owner of the note."  I referred to the document in reference to paying off a note, not contesting a foreclosure.  However, attorneys with experience in this area that I've consulted with have told me that courts in Washington State HAVE allowed similar documentation (probably the indemnification plus additional evidence such as assignment documents) to allow a foreclosure to continue when a lender can't produce the original note.

2.  While the only difference in using this strategy in a non-judicial foreclosure state is that you must proactively make the demand, this is actually a huge difference.  You would need to retain an attorney and file a lawsuit against the lender.  This can be very expensive, and since the outcome could be that the lender actually does produce the original note, you could be taking a big financial risk.

I specialize in short sales, and the majority of people I work with are in foreclosure.  I use an attorney to negotiate my short sales and I'm always open to strategies that benefit the seller/borrower.  The general consensus of attorneys I've spoken to is that a forensic loan audit followed with a lawsuit would have better odds of a beneficial outcome in Washington State than than filing a lawsuit and demanding that the lender produce the original note.  However, most sellers I work with are unable to pay the legal fees associated with filing any kind of lawsuit against the lender.

Oct 12, 2009 08:21 AM
Marty and Laurie Gale
Utah Realty - South Jordan, UT
Utah Realty | 801-205-3500 | UtahRealtyPlace.com

In truth, there is no evidence or statistical data to support claims that forensic loan audits -- even if performed by a licensed, legitimate and trained auditor, mortgage professional or lawyer -- will help homeowners get loan modifications or provide any other foreclosure relief.

May 07, 2010 02:01 AM
Tony and Suzanne Marriott, Associate Brokers
Serving the Greater Phoenix and Scottsdale Metropolitan Area - Scottsdale, AZ
Coldwell Banker Realty

The decision to pursue short sales rather than REOs was validated yet again in the past week, with the one two punch of the moratorium on Trustee Sales (no new inventory) coupled with the freeze on closing REO transactions that were already in contract with a Buyer (no closing, no revenue).  It can't be a pretty picture for large REO teams with a large fixed overhead - and who knows when things will start moving again?

Oct 17, 2010 07:36 AM
David Monroe
Keller Williams Realty - Kirkland, WA
Short Sale Real Estate Agent

The advantage seems to go back and forth between short sales and REOs.  One month, legislation or new bank/investor policies hurt the short sale market, then the next month something happens that hurts the REO market.

Oct 19, 2010 06:06 AM