Bank of America, N.A. v. The Grove Homeowners Association

CourtDistrict Court, D. Nevada
DecidedFebruary 10, 2020
Docket2:16-cv-02939
StatusUnknown

This text of Bank of America, N.A. v. The Grove Homeowners Association (Bank of America, N.A. v. The Grove Homeowners Association) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of America, N.A. v. The Grove Homeowners Association, (D. Nev. 2020).

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 DISTRICT OF NEVADA 7 * * * 8 BANK OF AMERICA, N.A., Successor by Case No. 2:16-cv-02939-RFB-BNW Merger to BAC HOME LOAN SERVICING, 9 LP Formerly Known As Countrywide Home ORDER Loans Servicing, LP; FEDERAL 10 MORTGAGE ASSOCIATION, 11 Plaintiffs, 12 v. 13 THE GROVE HOMEOWNERS 14 ASSOCIATION; SANDOR FEHER, 15 Defendants. 16 17 I. INTRODUCTION 18 Before the Court are Plaintiff Federal National Mortgage Association’s (“Fannie Mae”), 19 20 Motion for Summary Judgment and Plaintiff Bank of America N.A.’s (“BANA”) identical motions 21 for summary judgment. ECF Nos. 31, 32. For the following reasons, the Court grants the motions. 22 II. PROCEDURAL BACKGROUND 23 Plaintiffs BANA and Fannie Mae (collectively “Plaintiffs”) filed a complaint against 24 Defendants on December 19, 2016. ECF No. 1. In the complaint, Plaintiffs sought declaratory 25 26 relief that a nonjudicial foreclosure sale conducted under Chapter 116 of the Nevada Revised 27 Statutes (“NRS”) did not extinguish a deed of trust held on a Las Vegas property. Defendant The 28 Grove Homeowners Association (the “HOA”) answered the complaint on December 29, 2016. 1 ECF No. 7. On April 27, 2017, the Court granted a stipulation staying the case pending resolution 2 of pertinent Ninth Circuit and Nevada Supreme Court cases. ECF No. 23. Defendant Sandor Feher 3 filed his answer on May 30, 2017. ECF No. 24. The Court lifted the stay on April 10, 2019. ECF 4 No. 28. Plaintiffs filed their motions for summary judgment on May 17, 2019. ECF Nos. 31, 32. 5 6 III. FACTUAL BACKGROUND 7 The Court makes the following findings of undisputed and disputed facts. 1 8 a. Undisputed facts 9 This matter concerns a nonjudicial foreclosure on a property located at 3964 Pembridge 10 Court, Las Vegas, Nevada 89121. The property sits in a community governed by the HOA. The 11 12 HOA requires the community members to pay community dues. 13 Nonparty Dean Chiarelli borrowed funds from Colonial Bank, N.A. to purchase the 14 property in February 2007. To obtain the loan, Chiarelli executed a promissory note and a 15 corresponding deed of trust to secure repayment of the note. The deed of trust, which lists Chiarelli 16 as the borrower and Colonial Bank, N.A. as the lender, was recorded on February 23, 2007. On 17 18 October 9, 2010, MERS as nominee for Lender and Lender’s successors and assignees, recorded 19 an assignment of the Deed of Trust to BAC Home Loans Servicing LP. BAC Home Loan Servicing 20 LP later merged with BANA. 21 Chiarelli failed to pay the required HOA dues. From July 2011 through October 2012, the 22 HOA recorded a notice of delinquent assessment lien concerning past-due assessments, followed 23 24 by a subsequently recorded notice of default and election to sell and then a notice of trustee’s sale. 25 On or about February 14, 2013, a Trustee’s Deed Upon Sale was recorded, showing that Defendant 26 27 1 The Court takes judicial notice of the publicly recorded documents related to the deed of trust and the foreclosure as well as Fannie Mae’s Single-Family Servicing Guide. Fed. R. Evid. 201 (b), (d); Berezovsky v. Moniz, 869 F.3d 28 923, 932–33 (9th Cir. 2017) (judicially noticing the Guide); Lee v. City of Los Angeles, 250 F.3d 668, 690 (9th Cir. 2001) (permitting judicial notice of undisputed matters of public record). 1 Sandor Feher purchased the property for $8,000 at the HOA foreclosure sale held on January 30, 2 2013. 3 However, Federal National Mortgage Association (“Fannie Mae”) previously purchased 4 the note and the deed of trust in April 2007. While its interest was never recorded under its name, 5 6 Fannie Mae continued to maintain its ownership of the note and the deed of trust at the time of the 7 foreclosure sale. BANA serviced the note on behalf of Fannie Mae, at the time of the foreclosure 8 sale. 9 The relationship between Fannie Mae and its servicers is governed by Fannie Mae’s Single- 10 Family Servicing Guide (“the Guide”). The Guide provides that servicers may act as record 11 12 beneficiaries for deeds of trust owned by Fannie Mae. It also requires that servicers assign the 13 deeds of trust to Fannie Mae on Fannie Mae’s demand. The Guide states: 14 The servicer ordinarily appears in the land records as the mortgagee to facilitate 15 performance of the servicer's contractual responsibilities, including (but not limited 16 to) the receipt of legal notices that may impact Fannie Mae's lien, such as notices of foreclosure, tax, and other liens. However, Fannie Mae may take any and all 17 action with respect to the mortgage loan it deems necessary to protect its ... ownership of the mortgage loan, including recordation of a mortgage assignment, 18 or its legal equivalent, from the servicer to Fannie Mae or its designee. In the event 19 that Fannie Mae determines it necessary to record such an instrument, the servicer must assist Fannie Mae by [ ] preparing and recording any required documentation, 20 such as mortgage assignments, powers of attorney, or affidavits; and [by] providing recordation information for the affected mortgage loans. 21 22 The Guide also allows for a temporary transfer of possession of the note when necessary 23 for servicing activities, including “whenever the servicer, acting in its own name, represents the 24 25 interests of Fannie Mae in ... legal proceedings.” The temporary transfer is automatic and occurs 26 at the commencement of the servicer's representation of Fannie Mae. The Guide also includes a 27 chapter regarding how servicers should manage litigation on behalf of Fannie Mae. But the Guide 28 clarifies that “Fannie Mae is at all times the owner of the mortgage note[.]” Finally, under the 1 Guide, the servicer must “maintain in the individual mortgage loan file all documents and system 2 records that preserve Fannie Mae’s ownership interest in the mortgage loan.” 3 Finally, the Guide “permits the servicer that has Fannie Mae’s [limited power of attorney] 4 to execute certain types of legal documents on Fannie Mae’s behalf.” The legal documents include 5 6 full or partial releases or discharges of a mortgage; requests to a trustee for a full or partial 7 reconveyance or discharge of a deed of trust, modification or extensions of a mortgage or deed of 8 trust; subordination of the lien of a mortgage or deed of trust, conveyances of a property to certain 9 entities; and assignments or endorsements of mortgages, deeds of trust, or promissory notes to 10 certain entities. 11 12 In 2008, Congress passed the Housing and Economic Recovery Act (“HERA”), 12 U.S.C. 13 § 4511 et seq., which established the Federal Housing Finance Agency (“FHFA”). HERA gave 14 FHFA the authority to oversee Fannie Mae. In accordance with its authority, FHFA placed Fannie 15 Mae under its conservatorship in 2008. Neither FHFA nor Fannie Mae consented to the foreclosure 16 extinguishing Fannie Mae’s interest in the property in this matter. 17 18 b. Disputed Facts 19 The parties dispute the legal effect of the circumstances. 20 IV. LEGAL STANDARD 21 Summary judgment is appropriate when the pleadings, depositions, answers to 22 interrogatories, and admissions on file, together with the affidavits, if any, show “that there is no 23 24 genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” 25 Fed. R. Civ. P. 56(a); accord Celotex Corp. v. Catrett, 477 U.S. 317, 322 (1986).

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Bluebook (online)
Bank of America, N.A. v. The Grove Homeowners Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-america-na-v-the-grove-homeowners-association-nvd-2020.