Time-Sensitive: New York's 6-year statute of limitations may bar your lender's case. A free case review can reveal defenses that expire if not raised.

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New York Foreclosure Defense

Your Home.
Your Defense.
Your Fight.

Law Merchant Solutions is a Brooklyn-based community service provider. We review your foreclosure case, identify every viable defense, and assist in preparing written materials — so you can file it in your own name and fight back.

6
Year SOL Under CPLR 213(4)
2022
FAPA Enacted — Game Changer
45min
Consultation — Tue/Wed/Thu
FAPA 2022
Lenders can no longer unilaterally reset the statute of limitations clock.

Law Merchant Solutions is a community service provider — not a law firm — and does not provide legal advice or representation.

How We Fight Foreclosure in New York

01

Statute of Limitations

Under CPLR 213(4), lenders have exactly six years to foreclose after acceleration. We identify when that clock started — and whether it has expired.

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02

Standing Challenges

The plaintiff must prove it held the note at commencement. MERS assignments, endorsement gaps, and servicer affidavit deficiencies are all grounds for dismissal.

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03

FAPA Defenses

The 2022 Foreclosure Abuse Prevention Act closes lender loopholes. Voluntary discontinuance no longer resets the SOL. We apply FAPA to every pending action.

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04

Pleading & Waiver

Standing must be pleaded as an affirmative defense or it is waived. We ensure your answer is properly drafted to preserve every available defense.

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05

Acceleration Analysis

Not every lender letter constitutes valid acceleration. We scrutinize prior complaints and notices to determine exactly when — and whether — the debt was accelerated.

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06

Quiet Title Actions

Under RPAPL 1501, once a foreclosure is time-barred, we can bring a quiet title action to permanently discharge the mortgage from the property records.

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Legislative Update · 2022

FAPA Changed Everything for New York Homeowners

Governor Hochul signed the Foreclosure Abuse Prevention Act on December 30, 2022 — a sweeping law that permanently closed the loopholes lenders used to reset the statute of limitations clock.

  • Voluntary discontinuance no longer resets the six-year SOL clock
  • Lenders cannot unilaterally de-accelerate the debt to restart the timer
  • Savings statute protections are now restricted to original plaintiffs only
  • Once time-barred, all debt remedies — including note actions — are extinguished
  • Applies retroactively to all pending pre-2022 foreclosure actions
Full FAPA Analysis →
Key FAPA Provisions
CPLR 203(h)
No unilateral de-acceleration after accrual — overrides Engel
CPLR 3217(e)
Voluntary discontinuance does not toll or reset the SOL
CPLR 205-a
Savings statute — original plaintiff only, one extension max
RPAPL 1301(4)
No parallel actions; time-barred claim extinguishes all debt remedies
GOL 17-105
No implied SOL extensions — only express written agreement

The Case Law That Defines NY Foreclosure Services

View All Cases
2021
N.Y. Court of Appeals

Freedom Mortgage Corp. v. Engel

Established that default notices referencing acceleration as a future event do NOT constitute valid acceleration. Voluntary dismissal revoked acceleration — later overridden by FAPA.

SOL · Acceleration
2025
N.Y. Court of Appeals

Article 13, LLC v. LaSalle Natl. Bank

Confirmed FAPA's retroactive application is constitutionally valid. Lenders cannot challenge prior accelerations in quiet title proceedings. FAPA is settled law.

FAPA · Constitutional
2015
N.Y. Court of Appeals

Aurora Loan Services v. Taylor

Physical possession of the original note — not the mortgage — is the dispositive instrument for standing. Pre-commencement delivery of a blank-endorsed note establishes standing.

Standing · Note Holder
2020
N.Y. Court of Appeals

U.S. Bank v. Nelson

Lack of standing is waived unless clearly and expressly pleaded as an affirmative defense. A general denial of the complaint's standing allegations is insufficient.

Standing · Pleading
2026
App. Div. 2d Dep't

Deutsche Bank v. Gambino

Judicial estoppel requires a prior favorable judgment — mere inconsistency is insufficient. Servicer affidavits grounded in business records establish standing at summary judgment.

Standing · Estoppel
2011
App. Div. 2d Dep't

Bank of New York v. Silverberg

A MERS assignment of mortgage does not confer standing where MERS was only a nominee and lacked any interest in the underlying promissory note.

Standing · MERS
"The note — not the mortgage — is the dispositive instrument for standing to foreclose."
Aurora Loan Services v. Taylor, 25 N.Y.3d 355 (2015)

Deep Knowledge of New York Foreclosure Law

Foreclosure defense in New York requires mastery of a decade of shifting appellate doctrine — from pre-FAPA acceleration rules to the constitutional validity of FAPA itself. We know this body of law.

  • Thorough Case Timeline Review
    We trace every prior action filed against your property to identify the earliest valid acceleration date.
  • Note Chain-of-Custody Analysis
    We examine every assignment, endorsement, allonge, and custodial transfer to expose standing vulnerabilities.
  • FAPA Applied to Your Case
    We analyze whether FAPA's retroactive provisions create new defenses — even in cases pending since before 2022.
  • Answer Drafting & Motion Practice
    Every answer includes properly pleaded affirmative defenses. Every winnable motion is filed.
Schedule Your Consultation

How the Consultation Works

1

Book Your Review

Choose a 45-minute slot Tuesday, Wednesday, or Thursday — 11:00 AM to 3:00 PM ET. The $295 consultation fee confirms your session.

2

Share Your Documents

Bring your mortgage, note, all court papers received, and any prior lawsuit information. The more we have, the more precisely we can identify your defenses.

3

Defense Identification

We analyze your SOL timeline, standing vulnerabilities, FAPA applicability, and RPAPL notice compliance — identifying every viable defense in your specific case.

4

We Draft Your Brief

We assist in preparing written materials based on publicly available information and your input. You choose whether to use them in your own filing. You stay in control.

NY Foreclosure Defenses: Statute of Limitations & Standing

Our comprehensive 24-page practice guide covering CPLR 213(4), the Engel decision, FAPA's full impact, standing under Aurora, and defense checklists — available as a free PDF.

Download Free E-Book Explore Practice Areas
NY Foreclosure Defenses
Statute of Limitations & Standing
24 Pages · 7 Chapters · 2026 Edition
CPLR 213(4) Engel FAPA Aurora
Law Merchant Solutions

Is Your Foreclosure Time-Barred?

One 45-minute consultation can reveal whether your lender's case is fatally defective under New York law. The defenses are powerful — but they must be raised on time.

Consultations held Tuesday, Wednesday & Thursday · 11:00 AM – 3:00 PM ET · Secure Stripe payment · Confirmation sent by email