Ninth Circuit Finds That 1111(b) Deemed-Recourse Rights Do Not Survive Foreclosure Of Underlying Property

The Ninth Circuit recently announced in <I>Mastan v. Salamon (In re Salamon</I>) that a secured creditor with a nonrecourse mortgage cannot assert a claim for any deficiency if the underlying property is foreclosed on during the bankruptcy case. Here's an analysis of the decision.

9 minute readJuly 01, 2017 at 12:03 AM
By
Craig S. Ganz
Michael A. DiGiacomo
Ninth Circuit Finds That 1111(b) Deemed-Recourse Rights Do Not Survive Foreclosure Of Underlying Property

The U.S. Circuit Court of Appeals for the Ninth Circuit recently announced inMastan v. Salamon (In re Salamon) that a secured creditor with a nonrecourse mortgage cannot

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