WELLS FARGO BANK, N.A., ETC., APPELLANT,
v.
HERNANDEZ & SILVA ENTERPRISES, INC., ET AL., APPELLEES

Fla. 3d DCA | 2016-05-04
No. 3D15-702
Before ROTHENBERG, SALTER and SCALES, JJ.
193 So. 3d 67 Florida District Court of Appeal, Third District (2016) Positive Treatment
Cited by 3 cases

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Holding

A mortgagee's default notice is sufficient if it substantially complies with the mortgage's default notice provision, not strictly complies.


Facts & Procedural History

The trial court entered judgment for the defendant, finding the plaintiff's default notice insufficient as a matter of law. The plaintiff appealed thi…

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Opinion of the Court
SCALES, J.

SCALES, J.

In this foreclosure case, the trial court entered judgment for Appellee Hernandez & Silva Enterprises, Inc., based upon Hernandez & Silva’s defense asserting that the default notice. of Appellant Wells. Fargo Bank, N.A. was insufficient as a matter of law.

We reverse the trial court’s judgment because the record reveals that the trial court applied the incorrect legal standard in evaluating whether- Wells Fargo’s, default notice complied with Paragraph 22 of the mortgage, the default notice provision.

, We have'held'that a mortgagee’s default notice is sufficient if it substantially com*68plies with the mortgage’s default notice provision. Bank of N.Y. v. Mieses, 187 So.3d 919 (Fla. 3d DCA 2016); SunTrust Mortg., Inc. v. Garcia, 186 So.3d 1036 (Fla. 3d DCA 2016); Bank of Am. v. Cadet, 183 So.3d 477, 478 (Fla. 3d DCA 2016) (Mem); Bank of N.Y. Mellon v. Nunez, 180 So.3d 160, 162 (Fla. 3d DCA 2016). The trial court applied a strict compliance standard in the instant case.1

Reversed and remanded for proceedings consistent with this opinion.


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Citator

Cited By

  • Nationstar Mortg. v. Silva, 239 So. 3d 782 (Fla. 3d DCA 2018)
    …curity Instrument by judicial proceeding. “[A] mortgagee’s default notice is sufficient if it substantially complies with the mortgage’s default notice provision” – i.e. paragraph 22. Wells Fargo Bank, N.A. v. Hernandez & Silva Enterprises, Inc., 193 So. 3d 67, 67-68 (Fla. 3d DCA 2016). “Paragraph twenty-two is designed to ensure that a borrower receives essential information concerning his or her default, how to cure it, and his or her rights with respect to it. It is not a technical trap designed to…

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