Securitization Chain-of-Title: the US Bank v. Congress ruling

posted by Adam Levitin

Over on Housing Wire, Paul Jackson is crowing that chain-of-title issues in mortgage securitization are overblown because an Alabama state trial court rejected such arguments in a case ironically captioned U.S. Bank v. Congress.

But let’s actually consider whether the opinion matters, what the court actually did and did not say, and whether it was right.

Jackson and Yves Smith at Naked Capitalism have a running feud over the seriousness of chain-of-title problems, and I think that explains why Jackson is so worked up over this decision.  My own take is that it is much ado about nothing. Before anyone gets too excited one way or the other about this case, let’s remember that this is a ruling by one judge in an Alabama state trial court decision. It was unlikely to get much notice anywhere else in the country, but for the securitization industry grasping for a legal victory to parade around. This court ruling doesn’t have precedential value anywhere, including in Alabama, and its persuasive value is very low too, both on account of it being an Alabama state trial court and because of the quality of its analysis. Put differently, this ain’t an Ibanez type ruling, where a leading state supreme court issues a very thoughtful unanimous opinion.

Perhaps the most important thing to note about the opinion is what isn’t there. There was no consideration of the chain-of-title issue in the opinion. Let me repeat, the court said nothing about whether there was proper chain-of-title in the securitization. Instead, the court avoided dealing with it. That means that this ruling isn’t grounds for sounding the “all clear” on chain-of-title. At best, it is grounds for arguing that homeowners won’t be able to raise chain-of-title problems. As we’ve seen with Ibanez, that’s clearly incorrect, and a closer look at the Congress ruling shows that it might be an Alabama special, not applicable elsewhere.

Check out the rest of Professor Levitin’s analysis here…

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