Nationstar Mortgage v. Rfb Properties, LLC

CourtDistrict Court, District of Columbia
DecidedSeptember 30, 2024
DocketCivil Action No. 2020-2697
StatusPublished

This text of Nationstar Mortgage v. Rfb Properties, LLC (Nationstar Mortgage v. Rfb Properties, LLC) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nationstar Mortgage v. Rfb Properties, LLC, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NATIONSTAR MORTGAGE, LLC d/b/a Mr. Cooper, et al.,

Plaintiffs, No. 20-cv-02697 (DLF) v.

RFB PROPERTIES, LLC, et al.,

Defendants.

MEMORANDUM OPINION

Plaintiffs Nationstar Mortgage, LLC, the Federal National Mortgage Association (“Fannie

Mae”), and the Federal Housing Finance Agency (“FHFA”) bring this action against RFB

Properties to quiet title on a condominium property. Before the Court is the plaintiffs’ Motion for

Summary Judgment, Dkt. 62, and defendant RFB’s Motion for Judgment on the Pleadings,

Dkt. 63. For the reasons that follow, the Court will deny RFB’s motion and grant the plaintiffs’

motion.

I. BACKGROUND

A. Factual and Statutory Background 1

This title dispute arises out of the foreclosure sale of condominium Unit 233 (the

“Property”), located at 3701 Connecticut Avenue NW in Washington D.C. Amd. Compl. ¶ 1,

Dkt. 39. The Property is governed by the Connecticut Avenue Condominium Unit Owners’

1 The parties do not dispute the material facts underlying this action, see RFB Statement of Material Facts, Dkt. 63-3, and they largely rely on the same records. The plaintiffs also offer two declarations to establish Fannie Mae’s ownership of a deed of trust, see Dkts. 62-1, 62-2, a fact RFB does not contest. In addition, RFB provides two exhibits from Fannie Mae’s internal loan servicing guidance, but because the Court will not reach the field preemption issue, these two exhibits are not material to the Court’s opinion. Association (the “COA”) under the association’s bylaws. Id. ¶¶ 8, 21; see Amd. Compl. Ex. A,

Dkt. 39-1. In 2001, Deborah Tang obtained title to the Property, and in March 2007, she obtained

a $214,500 loan secured by a first deed of trust recorded against the Property. Amd. Compl. ¶ 21.

Fannie Mae acquired the loan and the deed of trust and has retained ownership for all times relevant

to this dispute. Id. ¶ 25. Fannie Mae contracted with Nationstar to act as the loan’s servicer,

managing day-to-day loan administration responsibilities. Id. ¶ 31.

During the 2008 financial crisis, Fannie Mae was placed into the conservatorship of FHFA

pursuant to the Housing and Economic Recovery Act, 12 U.S.C. § 4511 et seq. See Amd. Compl.

¶ 31. As conservator, FHFA succeeded to “all rights, titles, powers, and privileges of [Fannie

Mae],” including to the loan and secured first deed of trust recorded against the Property. See id.

¶ 27; 12 U.S.C. § 4617(b)(2)(A). The Housing and Economic Recovery Act provides that “[n]o

property” of an FHFA conservatorship “shall be subject to levy, attachment, garnishment,

foreclosure, or sale without the consent of [FHFA].” 12 U.S.C. § 4617(j)(3) (the “Federal

Foreclosure Bar”).

After Tang passed away, her estate conveyed the Property to Marie A. Canada in 2010. Id.

¶ 28. As the record owner, Canada was subject to all obligations of ownership, including the

payment of assessments under COA bylaws. See Amd. Compl. Ex. A. Canada failed to pay the

assessments owed. Amd. Compl. ¶ 38. As discussed infra § III.A, the parties contest as a legal

matter whether Canada’s failure to pay six months of assessments owed gave the COA a “super-

priority lien” under the D.C. Super-Priority Statute, see D.C. Code § 42-1903.13(a). Amd. Compl.

¶ 38; see also Opp’n to SJ at 21–22, Dkt. 66. Meanwhile, in April 2012, Canada also defaulted on

the Fannie Mae loan. Amd. Compl. ¶ 45. Fannie Mae appointed substitute trustees to administer

a potential foreclosure. Id.

2 In August 2014, the COA initiated foreclosure proceedings on what it viewed as its super-

priority lien. Amd. Comp. ¶ 38. It recorded a Notice of Foreclosure Sale with the D.C. Recorder

of Deeds, identifying $46,857.59 in unpaid assessments, interest, large charges, and attorneys’ fees

owed on the Property. Id. It also advertised the sale in a newspaper of general circulation and

asserted that the Property was being sold subject to “any other superior liens, encumbrances, and

municipal assessments.” Amd. Compl. Ex. G, Dkt. 39-7. The plaintiffs assert that the COA did

not seek FHFA’s consent to foreclose, Amd. Comp. ¶ 20, and RFB has presented no evidence that

FHFA agreed to a sale extinguishing Fannie Mae’s secured first deed of trust on the Property. At

the COA foreclosure sale held on September 23, 2014, RFB executed a purchase agreement for

the Property for $10,500—approximately 3.7% of its estimated $280,410 market value. Amd.

Compl. ¶ 42–43. The COA purportedly conveyed the Property to RFB via a trustee’s deed, which

RFB did not record with the District of Columbia Recorder of Deeds until November 13, 2017.

Id. ¶ 44.

In December 2016, Fannie Mae initiated foreclosure proceedings on its defaulted loan in

the D.C. Superior Court. See Federal National Mortgage Ass’n v. Marie A. Canada, Civil Action

No. 2016 CA-009203-R(RP); Amd. Compl. Ex. K, Dkt. 39-11. At that point, the outstanding debt

on the loan was $285,027.76. Amd. Compl. ¶ 47. The D.C. Superior Court entered an order

granting Fannie Mae’s Motion for Default Judgment and Decree of Sale of Real Property. See

Amd. Compl. Ex. K. Pursuant to the court order, Fannie Mae purchased the Property for $224,100

through a credit bid, 2 and the D.C. Superior Court ratified the sale. Amd. Compl. ¶ 47.

2 When a lender purchases property it is foreclosing upon through a credit bid, it typically waives the amount owed under the indebtedness in exchange for title ownership of the property. See generally Edward Brown, Best Practices for Credit Bidding at Foreclosure, American Association of Private Lenders, Aug. 19, 2019 (https://aaplonline.com/articles/strategy/best-practices-for- credit-bidding-at-foreclosure/). 3 B. Procedural History

In September 2020, the plaintiffs filed suit against the COA and RFB properties, seeking a

declaratory judgment to void the COA foreclosure sale and to declare Fannie Mae’s deed of trust

unextinguished. See Dkt. 1. RFB asserted crossclaims against the COA, including seeking the

“return of its purchase price paid for [the] Property” in the event the Court determined the

"foreclosure sale was void and unenforceable.” RFB First Ans. at 32, Dkt. 15. Nationstar, FHFA,

and the COA filed a putative Rule 41(a)(1)(A)(ii) stipulation of dismissal of all claims against the

COA, but the stipulation was not signed by plaintiff Fannie Mae. See Stipulation of Dismissal,

Dkt. 30. The Court subsequently dismissed the plaintiffs’ initial complaint without prejudice under

Rule 12(b)(6) for failure to assert a valid cause of action. See Dkt. 37 (neither the Declaratory

Judgment Act, 28 U.S.C. § 2201, or the Federal Foreclosure Bar, 12 U.S.C. § 4617(j)(3), provide

an independent cause of action).

The plaintiffs then filed an amended complaint asserting claims against only RFB

Properties. See Amd. Compl.

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