RAFAEL A. PAREJA AND MARIA D. ARROYO CISNEROS A/K/A MARIA D. ARROYO A/K/A MARIA E. ARROYO
v.
WILMINGTON SAVINGS FUND SOCIETY, FSB

Fla. 4th DCA | 2021-03-17
No. 20-0264
Florida District Court of Appeal, Fourth District (2021)

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Holding

A mortgagee may establish standing to enforce a note through evidence of a valid assignment, proof of purchase of the debt, or evidence of an effective transfer.


Headnotes

[1] A mortgagee seeking to enforce a note that is specially indorsed to another party may establish standing through evidence of a valid assignment, proof of purchase of the…

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Key Quotes

“Where a bank is seeking to enforce a note which is specially indorsed to another, it may prove standing through evidence of a valid assignment, proof of purchase of the debt, or evidence of an effective transfer.”

Court stating the legal standard for establishing standing in mortgage enforcement actions

Facts & Procedural History

Pareja and Arroyo Cisneros borrowed money and executed a mortgage secured by real property. Wilmington Savings Fund Society, FSB sought to enforce the…

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Opinion of the Court

PER CURIAM. Affirmed. See Wilmington Sav. Fund Soc’y, FSB v. Stevens, 290 So. 3d 115, 118 (Fla. 4th DCA 2020); Miller v. Kondaur Capital Corp., 91 So. 3d 218, 219 (Fla. 4th DCA 2012); see also Lamb v. Nationstar Mortg., LLC, 174 So. 3d 1039, 1040 (Fla. 4th DCA 2015) (“Where a bank is seeking to enforce a note which is specially indorsed to another, it may prove standing through evidence of a valid assignment, proof of purchase of the debt, or evidence of an effective transfer.”) (citation and internal quotation marks omitted). WARNER, DAMOORGIAN and FORST, JJ., concur.

* * * Not final until disposition of timely filed motion for rehearing.


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