HSBC wins New York appeal to expunge forged mortgage satisfactions

New York’s appellate court cleared forged satisfactions and blocked a stand‑alone second‑lien sale in a Brooklyn foreclosure on December 3, 2025.

This dispute traces back to a first mortgage from 2008. In November 2008, borrower Abul Hasan signed a $525,000 note secured by a first mortgage in favor of HSBC’s predecessor. In December 2009, three satisfactions of that first mortgage were recorded, and a foreclosure on the first mortgage was filed the same month. Ownership later changed. In January 2010, Waqas Ahmed signed a $417,000 note to Home Loan Center, Inc., secured by a second mortgage. In October 2013, JPMorgan Chase Bank, N.A., as assignee of the second mortgage, began a foreclosure on that lien and obtained a judgment of foreclosure and sale in June 2015. The first‑ and second‑mortgage actions were later consolidated.

USROF III Legal Title Trust 2015‑1, then holding the second mortgage, intervened in the first‑mortgage case. HSBC filed an amended complaint asserting that the three satisfactions tied to the first mortgage were fraudulent and moved to expunge them. In an order dated November 3, 2021, the trial court, among other things, in effect granted expungement as to USROF and removed…

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