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Bankers Trust Co. v. Payne
188 Misc. 2d 726 (N.Y. Sup. Ct. Kings County 2001) ; Clearinghouse Number: 54343
Description
Mortgagor’s Defense Under HOEPA and Allegation of Fraud in Inducement of Loan Preclude Summary Judgment of Foreclosure
Abstract
Based on homeowner’s defenses of payment, fraud, and
predatory lending, a New York court denied lender’s motions
to reargue and renew a prior summary judgment motion in a
foreclosure action. Defendant, an elderly man who had lived in his
house for over twenty years, claimed that he took out a $50,000
loan after plaintiff lender and its servicing agent’s
repeated solicitation. Defendant alleged that he received only a
portion of the loan and that plaintiff told him that he would
receive the remainder only if he took out an additional $25,000
loan; he took out the loan. Defendant alleged that he did not
receive funds from the second loan for $75,000 and could not afford
the $700-per-month payments but made payments for fear of losing
his home. Lender sued to foreclose, but the court held that it did
not make a prima facie case of homeowner’s default and could
not prove payment of all loan funds to homeowner. The court found
that defendant’s affidavit stating that he relied on
plaintiff’s misrepresentations asserted a cognizable defense
of fraud. The court held that defendant’s defense under the
Home Ownership and Equity Protection Act of 1994 (HOEPA) precluded
summary judgment for plaintiff. Defendant alleged that the loans at
issue violated HOEPA because of their increased rate of interest
upon default, their prepayment penalty, and their having been
extended to defendant without regard to his repayment ability.
Although plaintiff argued that the loan was not a mortgage under
HOEPA and that defendant ratified the mortgage loan by making
monthly payments, the court disagreed. Payments do not vitiate the
HOEPA defense, the court held.
