New Jersey Appellate Division Holds Bank Has Standing to Foreclose Even If Allonge to Note Was Not Affixed When Executed

Publisher: Pratt’s Journal of Bankruptcy Law

January 1, 2016

Day Pitney Author(s) Joy Harmon Sperling Sarah Sakson Langstedt

Joy Harmon Sperling and Sarah Sakson Langstedt wrote an article, “New Jersey Appellate Division Holds Bank Has Standing to Foreclose Even If Allonge to Note Was Not Affixed When Executed,” for Pratt’s Journal of Bankruptcy Law. The article analyzes the significance of the New Jersey Appellate Division’s recent decision in U.S. Bank National Association v. Morris Bayonne Associates I, LLC. In that case, the court ruled that the plaintiff in a foreclosure action had established a prima facie case for foreclosure even though the allonge to the note was not physically attached when the allonge was executed.

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