Legal Alert - No Need to "Show the Note" for a Non-Judicial Trustee's Sale


by Rick H. Herold and Colleen E. Schiman

On May 18, 2012, the Arizona Supreme Court issued an opinion in Hogan v. Washington Mutual Bank, N.A., et al., CV-11-0115-PR, holding that Arizona’s non-judicial foreclosure statutes do not require the beneficiary to show the original promissory note for the trustee to notice and conclude a non-judicial trustee’s sale.

[Read the full alert.]