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On November 3, in a case that was closely watched by industry participants, the Florida Supreme Court held that a mortgagor's default that occurs after the dismissal of a prior foreclosure action in which the loan payments were accelerated

On October 19, a divided Ninth Circuit ruled that a trustee of a deed of trust who takes action to initiate non-judicial foreclosure is not a "debt collector" under the Fair Debt Collection Practices Act (FDCPA). See Ho v. ReconTrust Co., NA, No., 10-56884 (9th Cir. Oct. 19, 2016).