Sarah Rowan


This Note argues that the Ninth Circuit erred in holding that the Federal Foreclosure Bar requires the Agency’s consent and that, even if it does require Agency consent, the Agency has not already impliedly consented. This Note also discusses the policy implications of the Berezovsky decision and of requiring the Agency’s consent before associations can foreclose. The Federal Foreclosure Bar completely undercuts the balance that priority lien laws created between lenders and associations, and it effec-tively prevents associations from enforcing their rights.

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