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Lost Note Affidavit

The sworn statement a foreclosing party files when it cannot produce the original Note — a frequent source of standing challenges.

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A Lost Note Affidavit (also called Affidavit of Lost, Stolen, or Destroyed Note) is a sworn statement filed by a foreclosing party that cannot produce the original Promissory Note. Under UCC § 3-309, a person not in possession of a negotiable instrument may enforce it if: (1) they were entitled to enforce it when the loss occurred, (2) the loss was not the result of a transfer or lawful seizure, and (3) they cannot reasonably obtain possession because the instrument was lost, destroyed, or stolen. The Lost Note Affidavit must detail: how the loss occurred, who last possessed the Note, the search efforts undertaken, and adequate protection (typically a bond) for the borrower against a future claim by another party presenting the Note. Lost Note Affidavits are a frequent target in foreclosure defense: a fraudulent or insufficient affidavit can support dismissal for lack of standing.

Purpose

  • 1Allow enforcement of a Note when the original has been lost, stolen, or destroyed
  • 2Provide the court with sworn testimony about the Note's loss and the foreclosing party's right to enforce
  • 3Protect the borrower from double liability by requiring an indemnity bond
  • 4Satisfy UCC § 3-309 requirements for enforcement of lost instruments

Who Prepares It

The foreclosing party (or its attorney) prepares the affidavit, which must be signed under oath by someone with personal knowledge of the Note's loss — typically a custodian of records for the plaintiff or servicer.

When It Is Used

Used when the foreclosing party files a foreclosure and does not have physical possession of the original Note. Filed with the complaint or in response to a demand for production of the original Note.

Legal Effect

If the court accepts the Lost Note Affidavit as sufficient under UCC § 3-309, the foreclosing party may enforce the Note despite not possessing it. However, the court may require a bond (typically 2x the Note amount) to protect the borrower. If the affidavit is insufficient — lacks personal knowledge, doesn't explain how/when the Note was lost, or describes the search inadequately — the court may dismiss for lack of standing. If the borrower can show the Note was actually transferred (not lost), the affidavit is fraudulent and grounds for dismissal.

Common Mistakes

Accepting a Lost Note Affidavit at face value — demand proof: who had the Note last? When? Where? How was it lost?
Not challenging the affiant's personal knowledge — the person signing must have actual knowledge of the loss; a robo-signer without knowledge makes the affidavit insufficient
Overlooking the bond requirement — demand a bond if the court allows enforcement; this protects you from double liability

Homeowner Rights

Right to challenge the sufficiency of the Lost Note Affidavit under UCC § 3-309
Right to depose the affiant about their personal knowledge of the Note's loss
Right to demand an indemnity bond to protect against double liability
Right to present evidence that the Note was transferred (not lost) — sales records, SEC filings, pooling and servicing agreements

Frequently Asked Questions

Does a Lost Note Affidavit automatically mean the foreclosing party lacks standing?

No — UCC § 3-309 specifically allows enforcement of a lost Note if the requirements are met. A properly executed Lost Note Affidavit with adequate protection can support standing. However, a Lost Note Affidavit that lacks personal knowledge, fails to explain the loss, or omits search details is vulnerable to challenge. The burden is on the foreclosing party to prove all elements of § 3-309 — the homeowner should force them to meet that burden.

What if the Note was not lost — it was sold?

If the Note was transferred (sold to a securitization trust, for example) and the foreclosing party claims it was lost, the affidavit is fraudulent. Evidence of a transfer can be found in SEC filings for the securitization trust, the Pooling and Servicing Agreement, and corporate records of the depositor and trust. If you can prove the Note was transferred — not lost — the Lost Note Affidavit is a fraud on the court, and the foreclosure should be dismissed.

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