Ocwen Loan Servicing, LLC v. Travis Oden and Tina M. Oden

2020 Ark. App. 384, 609 S.W.3d 410
CourtCourt of Appeals of Arkansas
DecidedSeptember 9, 2020
StatusPublished
Cited by2 cases

This text of 2020 Ark. App. 384 (Ocwen Loan Servicing, LLC v. Travis Oden and Tina M. Oden) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ocwen Loan Servicing, LLC v. Travis Oden and Tina M. Oden, 2020 Ark. App. 384, 609 S.W.3d 410 (Ark. Ct. App. 2020).

Opinion

Cite as 2020 Ark. App. 384 Reason: I attest to the accuracy and integrity of this document ARKANSAS COURT OF APPEALS Date: 2021-07-08 09:47:47 DIVISION III Foxit PhantomPDF Version: No. CV-19-539 9.7.5

OCWEN LOAN SERVICING, LLC; OPINION DELIVERED: September 9, AND WILMINGTON SAVINGS FUND 2020 SOCIETY, FSB, D/B/A CHRISTIANA TRUST, NOT IN ITS INDIVIDUAL APPEAL FROM THE SALINE CAPACITY BUT SOLELY IN ITS COUNTY CIRCUIT COURT CAPACITY AS OWNER TRUSTEE [NO. 63CV-16-729] OF MATAWIN VENTURES TRUST SERIES 2016-2 HONORABLE GRISHAM PHILLIPS, APPELLANTS JUDGE

V. AFFIRMED

TRAVIS ODEN AND TINA M. ODEN APPELLEES

ROBERT J. GLADWIN, Judge

On March 14, 2019, the Saline County Circuit Court granted judgment to appellees

Travis Oden and his wife, Tina, against appellants Ocwen Loan Servicing, LLC, and

Wilmington Savings Fund Society, FSB, d/b/a Christiana Trust, solely in its capacity as

owner trustee of Matawin Ventures Trust Series 2016-2 (collectively referred to as

“Ocwen”). The parties had filed competing motions for summary judgment related to a

promissory note and deed of trust secured by real property and executed on December 31,

2007, that obligated the Odens, who failed to pay. Ocwen accelerated the note on March

17, 2011, and filed a foreclosure complaint more than five years later on July 26, 2016. On

appeal from the circuit court’s finding that Ocwen’s complaint is barred by the statute of

limitations, Ocwen raises three points: (1) the enforcement of the deed of trust is not time- barred because Ocwen abandoned its prior acceleration; (2) Ocwen’s payment of taxes and

insurance on the property confirmed the debt; and (3) Ocwen has an equitable lien against

the property. We affirm.

I. Facts

On December 31, 2007, the Odens executed a note for $132,000 for the real

property at 830 Nash Cove, Alexander, Arkansas. The original lender was AAA Worldwide

Financial Company d/b/a Worldwide Mortgage Company. A deed of trust was executed

to secure the note, granting the lender a mortgage lien on the property. The lender’s loan

servicer, GMAC Mortgage, LLC, “force placed” insurance on the property, increasing the

loan payments. The Odens attempted to meet those increased payments but disputed the

force-placed insurance, and their payments were returned to them on several occasions.

The Oden’s last payment was in November 2010, and they stopped making payments

thereafter. GMAC declared the Odens in default on December 2, 2010. On March 17,

2011, the Odens’ loan accelerated, and the notice of acceleration states:

You are currently in default under the terms of your note and deed of trust/mortgage in that you have failed to make the payments due through the date of this letter. The debt has been accelerated. The amount of the debt that we are attempting to collect and the total amount currently due on your loan as of the date of this letter is $134,270.95.

On April 15, 2011, a “Trustee’s Notice of Default and Intention to Sell” was filed.

The notice declared that default had occurred and the indebtedness was “wholly due.” A

statutory foreclosure sale of the property was set for June 14, 2011, at the Saline County

Courthouse.

2 GMAC was sued in several class-action lawsuits, and it eventually filed for

bankruptcy. On February 16, 2013, Ocwen Loan Servicing, LLC, became the Oden’s loan

servicer, replacing GMAC. Ocwen had the same address and phone number as GMAC.

On July 27, 2016, a second “Trustee’s Notice of Default and Intention to Sell” was

filed, setting a statutory foreclosure sale for October 12, 2016. A “Delinquency Notice”

dated August 1, 2016, and addressed to the Odens states that as of July 30, 2016, they were

2068 days delinquent on their mortgage loan. Also on July 27, Ocwen gave notice to the

Odens that it would no longer service the loan payments after August 15 and that Kondaur

Capital Corporation would collect the payments after that date.1 But on August 24,

Kondaur’s letter to the Odens notified them that it had transferred the loan servicing back

to Ocwen as of August 16.2 The letter also stated, “As of August 19, the amount owed on

the account is $196,827.42.” On September 28, a notice of cancelation of the nonjudicial

foreclosure sale was filed.

The Odens filed an amended verified petition for declaratory judgment and request

for injunctive relief against Ocwen on June 23, 2017. They alleged that the statute of

1 The notice explained:

As a result of the default on the above mentioned mortgage loan, we made a claim for payment on the Federal Housing Administration (FHS) mortgage insurance. In connection with that claim, we assigned the mortgage loan to FHA. FHA sold the mortgage loan to Wilmington Savings Fund Society, FSB, d/b/a Christiana Trust, not in its individual capacity but solely in its capacity as Owner Trustee of Matawin Ventures Trust Series 2016-2, which is now the new owner of the mortgage loan. In connection with that sale, the servicing to the mortgage loan will be transferred, as set forth herein, to Kondaur Capital Corporation. 2 The Odens received a letter dated May 22, 2017, from Ocwen stating that the loan had been transferred to Ocwen effective May 9, 2017. 3 limitations to enforce a promissory note and deed of trust in Arkansas is five years. Ark.

Code Ann. § 16-56-111 (Repl. 2005); Ark. Code Ann. § 18-49-101 (Repl. 2015). They

claimed that when there is an optional acceleration clause in the deed of trust, the statute of

limitations accrues when the lender or servicer first accelerates the debt. United-Bilt Homes,

Inc. v. Sampson, 315 Ark. 156, 864 S.W.2d 861, 862 (1993). The Odens claimed that the

loan first became delinquent on December 2, 2010, and the loan was accelerated on March

17, 2011. Thus, Ocwen’s action to enforce the loan after March 17, 2016, is barred by the

statute of limitations. The Odens asked for a declaratory judgment finding that any future

foreclosure action is barred. The Odens also sought a preliminary injunction under Rule

65 of the Arkansas Rules of Civil Procedure (2019) to prohibit Ocwen from taking any

future action to enforce the loan.

Ocwen answered and pled the following affirmative defenses: (1) failure to state facts

sufficient to constitute any cause of action against it; (2) failure to mitigate damages; (3) no

duty to the Odens was owed or breached; (4) Ocwen’s acts or omissions were not a

proximate cause of the loss or damages for which the Odens sought recovery; (5) any

damages to the Odens were proximately contributed to or caused by the neglect of others

not subject to Ocwen’s control and were not caused by Ocwen; (6) equitable tolling; (7)

the statute of limitations ceased to accrue because Ocwen or their predecessors in interest

abandoned the acceleration by attempting to collect less than the accelerated amount of the

debt; and (8) the Odens reaffirmed the debt. Ocwen supplemented its answer with the

affirmative defenses that it had an equitable lien against the property and setoff or

recoupment.

4 On September 10, 2018, Ocwen moved for summary judgment that the note

remained enforceable because (1) the lenders had abandoned the prior acceleration of the

debt; (2) payment of taxes revived the debt; and (3) equity prevents the Odens from

recovering a windfall as a result of their failure to pay the debt. In its brief, Ocwen alleged

that after it acquired servicing, Ocwen sent many demands for payment that were less than

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Related

Turnbo v. Hamlett
2024 Ark. App. 128 (Court of Appeals of Arkansas, 2024)
Wilmington Savings Fund Society v. Milton A. Smith
2023 Ark. App. 326 (Court of Appeals of Arkansas, 2023)

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2020 Ark. App. 384, 609 S.W.3d 410, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ocwen-loan-servicing-llc-v-travis-oden-and-tina-m-oden-arkctapp-2020.