Distressed Real Estate

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Distressed Real Estate

Loss Mitigation Solutions

Short Sale is the sale of the property to a 3rd party. Generally by a realtor and for less than the remaining mortgage balance and either forgiving the balance, requiring the seller to come up with some amount or simply releasing the lien, but keeping the note alive. Short sales can be beneficial for the lender since judges are often reluctant to give deficiencies and the costs of litigation are saved.

Modification has become more popular. There are many government programs (HAMP, HARP, etc…) available for borrowers. Often borrowers can reduce interest rates, lower payments and put missed payments back into the loan.

Options other than statutory foreclosure

  1. Strict Foreclosure (common law and rare)
  2. Consent Foreclosure
  3. Deed in Lieu
  4. Bankruptcy (more on this later in the presentation)

Statutory foreclosure is governed by the Illinois Mortgage Foreclosure Law (“IMFL”), 735 ILCS 5/15-1101, et seq.

Strict Foreclosure is an old common law remedy for lenders and is expressly allowed under IMFL 15-1403

Cases relating to Strict Foreclosure: Great Lakes Mortgage v. Collymore, 302 N.E.2d 248 (1st Dist. 1973); Aletta v. Kyatt, 138 N.E.2d 695 (1st Dist. 1956)(only abstract available); Carpenter v. Plagge, 192 Ill. 82 (1901); Pruett v. Midkiff, 273 Ill.App 142 (4th Dist. 1933).

Obviously, none of these are current. However it is still good law and today’s market conditions make strict foreclosure a viable alternative. There are 3 elements required:

  1. The borrower (mortgagor) is insolvent.
  2. The property is worth less than the mortgage and outstanding taxes
  3. No deficiency judgment allowed against borrower.

The advantage is that after a shortened period of redemption – 30 to 90 days, the property reverts to the lender (mortgagee) without the need for a sheriff sale. This is shorter than the IMFL redemption period of 7 months from foreclosure or 3 months from entry of judgment (IMFL 15-1603). Also many properties are underwater, which would satisfy element 2. Also many borrowers have filed for chapter 7 bankruptcy, therefore element 3 is easily satisfied since no deficiency is allowed anyway, and presumably the borrowers were insolvent, since they filed for bankruptcy, satisfying element 1.

The problems are that there is little case law and judges are likely not familiar; other liens may not be extinguished; title companies could also be confused by this and it may be difficult to get title insurance as a result.

Consent Foreclosure is found in the IMFL 15-1402. If the parties (mortgagor and mortgagee) agree, the mortgagee can take the property free and clear of all junior liens (except for liens of the US).

Under the IMFL 15-1402(a), a consent foreclosure can be entered either with or without objection. In order to get a consent foreclosure without objection , the following elements must be present:

  1. It must be before the judicial sale.
  2. The lender must waive a personal deficiency against the borrower.
  3. The offer for consent foreclosure must be in writing in the complaint or a separate motion. Important that all parties get notice – especially non-records, unknowns and junior lienholders.
  4. Borrower consents (expressly)
  5. No other party objects

A consent foreclosure with objection is covered by 1402(b)

  1. Objection must be by a party in interest before judgment is entered. An evidentiary hearing is held.
  2. If good cause is shown, the court will not allow the consent judgment.
  3. If no good cause shown by objecting party or agreed to pay the redemption amount plus court costs and interest, then court shall grant the consent foreclosure, or
  4. If objecting party agrees to pay the redemption amount within 30 days, title will vest in objecting party once paid. Title is free and clear of any junior liens (other than the US government).

Under 1402(b)(3), if more than one party objects the opportunity to redeem (within 30 days) goes in order of lien priority. Note that an objecting party who does not redeem when given the opportunity may be liable for the interest and costs accrued during their 30 day redemption window to the party who successfully redeems.

What’s the difference between a consent foreclosure and strict foreclosure?

  • A consent foreclosure is statutory, strict is common law.
  • No redemption period in consent unless objections

Why use Consent Foreclosure?

  • Potentially quicker since no sale or redemption period.
  • Still wipes out junior liens (except the US government).
  • Potential carrot to offer to borrower – no deficiency. Many borrowers will not know that many judges will not give deficiencies anyway.

Issues to Consider

  • Junior lienholders must object otherwise extinguished with no opportunity to redeem.
  • No deed typically issued. Try and get borrower to issue deed or record judgment as a deed. May be possible to get judge to execute deed.
  • Make sure Consent judgment recites elements required by 1402(c):
    • Consent
    • Waiver of redemption
    • No deficiency (call this consideration, important especially if recording)
    • Legal description and common address (important especially if recording)
    • No objections
    • Possession

Case law for consent foreclosure: In re Brooks, 324 BR 56 (ND IL BK 2005), Applegate Apt. v. Commercial Coin, 276 Ill.App.3d 433 (1st Dist. 1995)

Deed in Lieu

A Deed in Lieu (“DIL”) is governed by the IMFL 15-1401. This is where a Lender accepts a deed from the Borrower instead of foreclosing and generally in satisfaction of the underlying debt. Note that to keep a borrower or guarantor on the hook for the unsatisfied portion of the underlying debt an additional agreement must be executed contemporaneously with the deed. Lender takes the property subject to any other liens on the property.


What is needed? 

Offer and acceptance.


Who should make the offer?

Ideally the Borrower makes the offer and the Lender accepts. This cuts off the Borrower from claiming duress and insures that the offer is voluntary. If the Borrower makes the offer it should state the reason for the offer, that the offer is voluntary, that the property is underwater, no other liens.

Never take the Borrowers word. The Lender should get their own appraisal to make sure that the property is underwater and perform a title search to make sure no other liens on the property. Getting an appraisal to verify the property is underwater can protect the Lender if the DIL is accepted and the Borrower files for bankruptcy within the 90 days to one year.

Remember that even if there are other liens discovered – a consent foreclosure is still a valid option.


Why a DIL?

  • Borrower is generally released from a deficiency
  • Faster for all parties involved. Bank can turn around and resell the property quicker.
  • Cheaper – less legal fees and costs. Especially true when judges are reluctant to give our deficiencies anyway. Just increases the Bank’s costs with little chance for recovery.


Note at the end of 1401 a Lender’s acceptance of a DIL does not constitute merger of the Lender’s interest as to junior lienholders. What this means is that a junior lienholder does not now become the senior lienholder just because the Bank settled with the Borrower. If necessary, the Lender could still foreclose against the junior lienholder(s) to eliminate them. Of course, if a junior lienholder is known, it is best to not continue with the DIL anyway.


Case law for DIL: Flora Bank v. Czyzewski, 222 Ill.App.3d 382 (5th Dist. 1991), Olney Trust Bank v. Pitts, 200 Ill.App.3d 917 (5th Dist. 1990), ZDE Investments v. Bosco, 2012 Ill App (1st) 120975-U (2012 Unpublished Opinion)

Pitfalls in Foreclosure Procedures

Borrowers in the Military

The Servicemember Civil Relief Act (SCRA, 50 USC Appendix 501-596) protects service members who are deployed on active duty. Most civil cases against servicemembers are suspended while they are on active duty and up to 90 days after deployment ends. The Act is fairly long. It is best to verify if one of the parties is a servicemember athttps://www.dmdc.osd.mil/appj/scra/single_record.xhtml and then consult the text of the Act for specifics.


Liens by the US Government – Federal Tax Liens

Only a judicial sale can remove the government’s lien. See 28 USC 2410. The US must be listed as a party and service must be made appropriately – send to local US Attorney and to Attorney General via registered or certified mail. Government has 60 days after service to respond. Government has a 120 period of redemption or the State Law period from the date of sale, whichever is longer for IRS liens.



Under the Applegate case listed above, it is important to list actual names of tenants and not just lump them in with the unknowns. If not properly noticed, the tenant’s interest is not foreclosed.

Leases executed prior to a mortgage has a superior interest to the mortgage, and even with a judicial sale you take subject to that lease. (See Kelley/Lehr v. O’Brien, 194 Ill.App.3d 360 (2nd Dist. 1990) and IMFL 15-1504)

Must comply with the Federal “Protecting Tenants at Foreclosure Act” of 2009. Leases entered into prior to foreclosure must be allowed to stay for balance of the lease.


Redemption Issues

The equity of redemption always exists. Do not try and waive it in a mortgage document. The equity of redemption runs until the foreclosure sale. A mortgage, installment contract, agreement that is secured by a property cannot have language that purports to quitclaim or revert the property back to the lender. (See First Illinois Bank v. Hans, 143 All.App.3d 1033). This is against public policy and is void. Note that as part of the foreclosure process itself this can be waived by the borrower or shortened as described above for DIL, Consent or Strict Foreclosures.



  • Always seek Relief from Stay if either Borrower or any Guarantor is in an active bankruptcy.
  • If Borrower is in a Ch 13 and current post-petition, no foreclosure possible.
  • Never, ever seek a deficiency against a borrower who was discharged and did not reaffirm.



There are a few different types of injunctions: Temporary Restraining Order (TRO), preliminary, permanent, and bankruptcy. TROs are ex parte, there was no time to give notice. Preliminary requires all parties to have notice (sometimes called a Motion to Stay in foreclosures). Permanent is very rare in a foreclosure proceeding.

The most common examples of injunctions in foreclosure are either bankruptcy or divorce. In order to obtain an injunction in state court, 4 elements must be satisfied:

  1. The party seeking the injunction will likely succeed on the merits.
  2. The party seeking the injunction must have a right or interest that requires protecting
  3. Irreparable harm if no injunction
  4. No other remedy at law (In re Marriage of Elliot, 265 Ill.App.3d 912. 914 (1st Dist. 1994) citing Cross Wood Products v. Suter, 97 Ill.App.3d 282 (1981).

In Elliot an injunction issued after the foreclosure was consolidated with the divorce proceeding. However, the injunction was overturned since there no definite timeframe, the Lender was not adequately protected, and there was not a sale or refinance pending.

In bankruptcy the injunction is automatic under 362 of the bankruptcy code. (more on this later in the presentation)


Possession during foreclosure

Under the IMFL 15-1701(b)(1) and (2) there are different presumptive rights to possession depending on whether or not the property is residential. If the property is residential, the presumption is that the Borrower (homeowner) is entitled to possession. To overcome that, the Lender must show the following:

  1. Good cause
  2. The mortgage allows the Lender to have possession
  3. The Lender has a reasonable probability of success


For nonresidential property, the Lender is presumed to be entitled to possession if:

  1. The Mortgage allows it.
  2. The Lender has a reasonable probability of success


The Borrower can overcome this but they must object and show good cause. (Bank of America v. 108 N. LaSalle, 401 Ill.App.3d 158, 164 (1st Dist. 2010) citing Travelers Ins. V. LaSalle Nat. bank, 200 Ill.App.3d 139, 143 (2nd Dist. 1990)).


Most mortgages contain language now that allows the Lender to take possession in a foreclosure proceeding. Also, as stated in Bank of America , if the Lender can establish a default, then the Lender has established a reasonable probability of success. All that leaves is good cause. Which party has to show it depends on if the property is residential or not. In a commercial setting, generally the Borrower will attempt to show good cause via some sort of affirmative defense. As the Travelers case illustrated it is important for affirmative defenses and answers to be verified and to use a counter-affidavit against the affidavit submitted as part of the Motion for Possession. Also affirmative defenses must contain factual allegations and not be simply conclusory. Also, the affirmative defenses or other good cause must not simply attempt to shift the burden back onto the Lender (Bank of America, 401 Ill.App.3d 158 at 176). Also, the Lender is not required to show or allege any fraud, mismanagement or waste being committed by the borrower. (Id.) Also of note is that simply alleging or even demonstrating that the Lender is adequately protected is irrelevant under the IMFL. (Travelers, 200 Ill.App.3d 139, 144).


Resetting the Sale Date

It is common for a judicial sale to get rescheduled after publication is complete. Be careful when rescheduling for more than 60 days past the original publication date. If a sale is pushed back further than 60 days then you will need to republish. IMFL 15-1507. Case law goes both ways on what can happen in a failure to republish. In a pre-IMFL case, failure to republish was adequate reason to set aside the sale. First Federal Savings v. Chapman , 116 Ill.App.3d 950 (3rd Dist. 1983). Generally, the price bid at a judicial sale is presumptively a sufficient amount. However, courts have held that lack of republication and a sale price less than the appraised value could be “good cause” for setting aside a sale. GMB Financial v. Marzano, 385 Ill.App.3d 978, 997 (2nd Dist. 2008), see also Cragin Federal Bank v. American Natl. Bank, 262 Ill.App.3d 115, 121 (2nd Dist. 1994).

Complicated Priority Disputes

The IMFL 15-1301 sets the general rule that the lien is effective with respect to 3rd parties when the mortgage is recorded in the county where the real estate is located. IMFL 15-1302 is for certain future advances (such as a HELOC). The Illinois Conveyances Act 765 ILCS 5/30 also controls mortgage priority. The general rule of first in time, first in right only goes so far. There can be issues with the recorded document itself. What if the mortgage was really a refi or renewal? What if all of the lien holders are not mortgages: memorandums of judgment, mechanics liens, or condo/homeowners associations?

In most cases if there is an issue over priority it is resolved before sale; however the IMFL 15-1506(h) does allow the court to delay deciding until the sale confirmation. Under 1506(h), a party in interest can seek court approval to defer establishing priority until after the sale. (NBD Highland Park Bank v. Wien , 251 Ill.App.3d 512, 517-8 (2nd Dist. 1993). IMFL 15-1508(b) also provides that the order confirming sale may determine the priority of parties who deferred under 1506(h). Id.

There can be issues with the recorded mortgage that would also defeat first in time, first in right. If the mortgage had one value on its face, but the terms of the document allowed for future advances to exceed that amount, then that recorded mortgage would not be sufficient to give notice to subsequent lienholders. ( Northridge Bank v. Lakeshore Commercial , 48 Ill.App.3d 82 (1st Dist. 1977).

A home equity line of credit or reverse mortgage are covered under the IMFL 15-1302. These types of mortgages are recorded with maximum lien amounts – the maximum amount the borrower can draw upon. These are effective against subsequent lienholders even if there was no balance owed at the time.

What if there is a mortgage and a mechanics lien and the equity in the property is insufficient to satisfy both amounts? The Mechanics Lien Act (770 ILCS 60/16) modifies the first in time, first in right rule. LaSalle Bank v. Cypress Creek , 242 Ill.2d 231, 237 (2011). Under the Mechanics Lien Act, “each mechanics lien claimant has priority only to the extent of the increased value of the property due to that claimant’s improvements on the property. Id. at 238 (emphasis in the original). It is important to note that the value of the mechanic lien claim may not simply be equal to the amount of the lien itself, it could be limited to the increased value of the property as a result of the improvements. The court in the LaSalle case looked at the value of the property prior to the improvements and then the value after the improvements were done to determine the extent of the mechanics lien claim relative to the amount the property was sold for at the sale. Id . at 291.

If a mortgage is a renewal of a previous note then it will generally have priority back to the original note recording date. Also if a mortgage is sold or assigned, it maintains the original priority date. It is important to note that the assignment does not need to be recorded to maintain this priority; however, it will be necessary to produce the assignment at foreclosure to show that the Plaintiff actually has standing to bring the suit.

Refinancing can also change the priority contrary to the order that the mortgages were recorded. Under the doctrine of subrogation, if a lender pays off a previous lienholder, that lender assumes the priority of the lender it paid off to the extent of the previous lender’s lien. (See Aames Capital v. Interstate Bank of Oak Forest , 315 Ill.App.3d 700 (2nd Dist. 2000). There are two types of subrogation: conventional/contractual and equitable. Id . at 706. Conventional or contractual is a typical refi. Ideally the new lender references the previous lender that it is paying off as part of the refi and a subrogation agreement is recorded. However, if you have that then there’s no complicated priority dispute. The issue comes up when there is no subrogation agreement recorded. This was the issue in Aames.

There are no hard and fast rules for equitable subordination, although unjust enrichment is a key aspect, and not a lot of case law. Id. One of the few cases to address this had to do with a combination of known and unknown mechanics liens. That case involved a lender paying off known mechanics liens but not paying off unknown liens. In that case, the new lender’s mortgage was found to be superior the unknown mechanics liens to the extent of the amount it paid off on the known liens. Id . citing Detroit Steel v. Hudes , 17 Ill.App.2d 514 (1958).

Condo and Home Owner Association are generally considered to run with the land and have priority over subsequent mortgages as long as the association bylaws and declarations were recorded first. St Paul Federal v. Wessby , 149 Ill.App.3d 1059, 1062-3 (1st Dist. 1986). This was applying the Illinois Condominium Property Act. However, the lien does not come into existence until they become due and are not paid. Id . at 1068-9.

Effects of Bankruptcy on Foreclosure

Any bankruptcy (7, 11 or 13) stops a foreclosure action in its tracks. This is because the automatic stay prevents any further state court action while the bankruptcy is active, unless the creditor moves for relief from stay. A bk can stop the foreclosure any time before the sheriff sale. It will not generally help after the sale is held, unless the state court judge would have adequate reason to not confirm the sale.


Non-Residential Leases in Bankruptcy

What happens to a lease when lessee files bankruptcy?

Pre-BAPCPA : Code allowed 60 days, subject to extension

Post-BAPCPA : Time to assume or reject is now 210days

  • The first 120 are given automatically
  • The next 90 may be decreed for cause
  • Additional time requires L(or) consent


Consequences of assumption

+ Requires curing pre-petition defaults to Lessor – who gets its distributions first

+ Creates administrative liability for remaining rent subject to a new 2-year cap

Consequences of rejection

+ Makes no difference if done timely + If rejected following initial assumption then

  • 2 years of rent payments will be treated as an administrative claim and paid out automatically
  • The landlord has a §502(b)(6) claim for any remaining rent

Sale of Real Estate in Bankruptcy

How does the filling of a bankruptcy affect the debtor’s ability to sell real estate?

Conventional or “Broker Based” Sales

  • + Listing Agreements
  • + Commissions to pay
  • + MLS, other marketing
  • + Opaque negotiations
  • + May or may not be arm’s length

RE Sales in Bankruptcy

  • + Open bids: transparency
  • + Bidders must be “qualified”
  • + Court and Trustee approval
  • + T(ee) must get “best deal”
  • + “Fair” Pricing is an issue

What Happens When Debtors Refinance

Can a Trustee compel debtor to pay more into their Plan of Reorganization when they conduct a cash-out refinance?


In re Drew , 325 BR 765 (ND IL 2005) J. Squires In re Powers , 140 B.R. 476 (ND IL 1992)


In re Drew : J. Squires notes that, according to the 7th Circuit, the answer depends on whether §1329 applies to those proceeds, making them assets of the bankruptcy estate subject to distribution in a Plan of Reorganization under §1306. In re Witkowski , 16 F.3d 739 (Cir. 7, 1994).


Relief available under §1329 when §1322(a), (b), §1325(a), and §1323(c) have been satisfied.


The upshot Yes . The proceeds of cash-out refi constitute property of the Estate just as gifts, inheritance, and windfalls like lottery winnings do. Therefore the Trustee may seek to have them distributed through the Plan of Reorganization.


See In re Euerle , 70 B.R. 72 (Bankr.D.N.H.1987) (inheritance); In re Koonce , 54 B.R. 643 (Bankr.D.S.C.1985) (lottery); Doane v. Appalachian Power Co./In re Doane , 19 B.R. 1007 (W.D.Va.1982) (money loaned by a relative).


DIS : Post­petition acquisitions do not become part of the Estate in a Chapter 7 or Chapter 11 case.

Lien Stripping in Ch. 13

§1322(b)(2) specifies that a Plan of Reorganization may not modify a claim that is “secured by an interest in the debtor’s principal residence.” So is it possible to strip a second or third mortgage?


In re Fenn , 428 BR 494 (ND IL ED 2010) J. Cox


In re Fenn : Judge Cox observes that according to §506(a) a claim is “secured” only to the extent of the creditor’s interest in the bankruptcy estate’s allowed interest in that property. According to §506(d) creditor claims are presumed to be allowed unless


+ singled out for disallowance in §502(b)(5) or §502(e) + OR the creditor fails to file Proof of Claim per §501


Once the allowed secured claim is identified under §506(d), §§1322(b)(2) and 1325(a)(5) allow the Chapter 13 debtor to treat such undersecured liens as partially or entirely unsecured so that they can be paid at the same rate as General Unsecured Creditors (GUCs) in the Plan of Reorganization.


Therefore : Where collateral is fully encumbered by a 1st lien, leaving no value to secure junior liens, said junior liens are effectively unsecured and can be modified (“stripped”) and paid via the Plan of Reorganization.


Dis : Lien stripping not available in Chapter 7 per US S.Ct. Dewsnup v. Timm , 502 U.S. 410, 112 S.Ct. 773, 116 L.Ed.2d 903 (1992).


Can a Ch. 13 Debtor Defeat a Due-On-Sale-Clause by Curing the Mortgage Defaults of the Property’s Owner ?


If Ch. 13 Debtors living in property transferred by owner, who was delinquent at the time, pay off owner’s arrears in Plan of Reorganization, can mortgagee force lump-sum payment via “due­on­sale” clause?


In re Tewell , 355 BR 674 (ND IL ED 2006) J. Squires


§362(a) of the Bankruptcy Code (the Automatic Stay) provides for relief from the Stay on request of a party in interest following notice and a hearing for any of the following reasons:


+ For cause, including lack of adequate protection of creditor’s interest in the property (i.e. waste, failure to maintain insurance, failure to make mortgage payments, etc.); OR


+ When the debtor has no equity in the property and the property Thus, § 362(d) provides two grounds under which relief from the automatic stay may be granted.


“Cause” has not been clearly defined and is determined on a case­by­case basis. In re Fernstrom Storage & Van Co ., 938 F.2d 731, 735 (7th Cir.1991).


The second ground is that the debtor does not have equity in the property and the property is unnecessary to an effective reorganization. 11 U.S.C. § 362(d)(2).


The first ground is the one applicable here: whether the Creditor can assert its rights under the due­on­sale clause as “cause” for relief from the stay under § 362(d)(1).

Post Foreclosure Issues

Eviction Issues


Under the IMFL 15-1701(b), the purchaser is entitled to possession 30 days after the sale is confirmed against all parties whose interests were terminated by court order. If it is discovered that are other unknown occupants, under section 1701(h) a supplemental petition can be brought within 90 days of confirmation. Must have service on these new parties. The proceeding is similar to a forcible entry and detainer action. It is important to file the supplemental petition within the 90 days, otherwise the new owner must file the 90–day notice of intent as required by 1701(h)(4). This exact issue was addressed when the Cook county sheriff refused to evict someone for lack of this notice. 1840 Maple Ave v. West , 2012 IlL.App 103120-U (1st Dist. 2012). There are issues with evicting unknowns under 1508(g). (SeeFairbanks Capital v. Coleman , 352 Ill.App.3d 550 (1st Dist. 2004)).


Under the Applegate case listed above, it is important to list actual names of tenants and not just lump them in with the unknowns. If not properly noticed, the tenant’s interest is not foreclosed.


Leases executed prior to a mortgage has a superior interest to the mortgage, and even with a judicial sale you take subject to that lease. (See Kelley/Lehr v. O’Brien, 194 Ill.App.3d 360 (2nd Dist. 1990) and IMFL 15-1504)


Must comply with the Federal “Protecting Tenants at Foreclosure Act” of 2009. Leases entered into prior to foreclosure must be allowed to stay for balance of the lease.


Securing the Property


Once the sale is confirmed, the highest bidder at the judicial sale is now the title owner of record. Possession is generally stayed for 30 days (see eviction issues above). After the 30 days is up, the sheriff can be contacted to evict the homeowners. Note that this will generally take more time if the sheriff is backed up.


After the buyer gains possession, they can and should change the locks and inspect the property. There could be extensive damage and if during the winter, take steps to winterize the property to prevent plumbing damage.


Property Preservation Issues


The property is now the buyer’s responsibility. Getting insurance is the minimum. Check with local ordinances to see if vacant property needs to be registered. If the original homeowner is now a tenant, there may be local permits required since the property is now a rental. Make sure the property is kept up, lawn is mowed and snow removed. Many cities will fine the owner of record for failure to follow these rules. Also, if the new buyer is now a landlord, they will be responsible for keeping the property up and “habitable”. Tenants can and will complain to the local building inspectors and larger cities will have tenant problem numbers to call.


Liability for HOA, Taxes, etc.


The buyer is now the owner of record and is responsible for HOA dues, taxes, etc. The judicial sale does not extinguish or satisfy past due taxes or a property that has already been sold for taxes. The buyer should make sure to pay or redeem the taxes as soon as possible. Especially if they need to redeem, the Illinois statutory interest rate is very high in Illinois. If possible, past due taxes should be paid before the sale and added into the judgment amount.


Also the buyer should keep up with HOA dues and if the property is part of an HOA, it is even more important to keep the property maintained, many HOA can fine an owner for property not in compliance with the by-laws.

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