“Deed in a Box”

I was happy to present on a recent “Deed in a Box” case (more on that below) at the American College of Mortgage Attorneys annual meeting on the Professors’ Panel along with

  • Steven W. Bender, Associate Dean for Planning and Strategic Initiatives and Professor of Law; Co-Faculty Director of Critical Justice Initiative, Seattle University School of Law, Seattle, WA
  • R. Wilson Freyermuth, Robert L. Hawkins/Dale A. Whitman Chair Emeritus, Curators Teaching Professor Emeritus, University of Missouri School of Law; Executive Director, Joint Editorial Board of Uniform Real Property Acts, Columbia, MO
  • Julia P. Forrester Rogers, Provost Faculty Research Fellow and Professor of Law, SMU Dedman School of Law, Dallas, TX

Professor Bender explained that Vargas v. RRA CP Opportunity Trust 1 (Wash. 2026), now under reconsideration, could limit nonjudicial foreclosure to holders of negotiable instruments, which would push lenders on HELOCs and most commercial loans toward receiverships and mezzanine structures and expose similar “holder” statutes in other states.

Professor Freyermuth provided an update on the Restatement (Fourth) of Property (for which he is an Associate Reporter). The Restatement 4th will, for the first time, address when a long delay in a foreclosure operates to time-bar the right to foreclose.

Professor Forrester Rogers previewed the Uniform Law Commission’s draft Deed Fraud Act (for which she is the Reporter), which pairs prevention tools (owner notification, title freezes, a known-filer program, and notarial verification) with an expedited court proceeding to void fraudulent deeds and mortgages.

Deed in a Box

My presentation focused on Shanghai Commercial Bank Ltd., New York Branch v. New Tent, LLC, No. 850240/2024 (Sup. Ct. N.Y. Cnty. June 13, 2026), in which Justice Masley of the Commercial Division held that a deed in lieu of foreclosure delivered as consideration for a forbearance agreement is a mortgage under Real Property Law § 320. The decision appears to be the first in New York to hold this expressly in the forbearance context.

The facts will be familiar to anyone who has worked out a troubled loan. The lenders had made about $75 million in loans secured by a mortgage on 335 West 35th Street in Manhattan. After the borrowers defaulted, the parties signed a forbearance agreement. In exchange for the forbearance, the borrowers delivered a conveyance in lieu of foreclosure that would take effect if the loan was not repaid by the end of the forbearance period. The agreement said the conveyance was absolute “in fact as well as in form” and was not intended as a mortgage or security instrument. The borrowers did not pay and then refused to cooperate with recording, so the lenders sued.

The court’s reasoning follows a long line of New York cases, including Basile, Leonia Bank, Patmos, and RTT Holdings. Those cases hold that a deed given to secure a debt creates only a mortgage, however it is labeled. Here the conveyance was given in exchange for forbearance on an existing, defaulted obligation, so it functioned as security for the debt, and the disclaimer could not change that.

The practical lesson is that a deed in lieu is not a shortcut around a NY foreclosure in a forbearance deal. Lenders who want speed should consider other tools, although they have their own limitations: a consent judgment of foreclosure, an accommodation pledge of the borrower’s equity interests that can be enforced through a UCC sale, or an assignment in lieu of the membership interests. The lenders have appealed to the First Department, so there may be further developments regarding the “deed in a box” in New York.

Foreclosure Alternatives


Realtor.com quoted me in 3 Foreclosure Alternatives: What to Do Before Your Mortgage Goes Underwater. It opens,

Maybe you’ve missed a couple of monthly mortgage payments. Maybe a notice of default from your lender is looming right now. You understand the severity of the situation, but what most homeowners don’t know is that foreclosure is not the only option you have when you’re no longer able to afford your house.

The first step for anyone in risk of foreclosure is to get in contact with your lender. This shows that you are aware of the problem and committed to finding a solution—and trust us, that will go a long way. The earlier you reach out, the greater shot you have of amicably rectifying the problem.

After you speak with your lender, your lender will lay out your options, including the foreclosure alternatives that you might be able to take advantage of. Let’s take a closer look at some of the alternatives so you—and your credit history—don’t suffer the ultimate blow.

1. Standard sale or rental

If your home is currently valued at more than you owe and if you are up to date on your mortgage payments (but you anticipate that paying your mortgage could become a problem), you can hold out as long as possible for a buyer.

You can also try to rent out the home to cover the mortgage payments until the house sells, says Carolyn Rae Cole, a Realtor® with Nourmand & Associates. In the end, virtually all homes eventually sell—it’s just about pricing.

2. Short sale

When a home has fallen in value and is priced so low that there isn’t enough equity to cover the mortgage, you might have the option to conduct a short sale. It’s also known as going “underwater.” This means the lender agrees to accept less than the amount the borrower owes through a sale of the property to a third party.

A short sale works like this: A specialist brokers a deal with the mortgage lender to sell the home for whatever the market will bear. If the amount of the sale is for less than what’s owed on the mortgage, the lender gets the money from the sale and relinquishes the remaining debt. (This means you won’t owe anything else.) In a short sale, the lender usually pays for the seller’s closing costs. A traditional sale takes about 30 to 45 days to close after the offer is accepted, whereas a short sale can take 90 to 120 days, sometimes even longer.

Sellers will need to prove hardship—like a loss of primary income or death of a spouse—to their lender. In addition to explaining why they’re unable to make mortgage payments, sellers will have to provide supporting financial documents to the lender to consider for a short sale.

3. Deed in lieu of foreclosure agreement

A deed in lieu of foreclosure is a transaction between a lender and borrower that effectively ends a home loan. Essentially both parties agree to avoid a lengthy foreclosure proceeding by the borrower voluntarily turning over the home’s deed to a lender, says professor David Reiss of Brooklyn Law School
. The lender then releases the borrower from any further liability relating to the mortgage. However, if the property is worth significantly less than the outstanding mortgage, the lender may require the borrower to pay a portion of the remaining loan balance.

You might be eligible for a deed in lieu if you’re experiencing financial hardship, can’t afford your current mortgage payment, and were unable to sell your property at fair market value for at least 90 days.

Bottom line: This agreement is a negotiated solution to a bad situation—borrowers who have fallen behind on their payments are going to lose their house and the lender is not getting paid back in full.