Defendants, De.O and Do.O admits the jurisdictional allegations in the complaint. No Transfer of the Note (Privity) = Lack of . What are the affirmative defenses to a foreclosure lawsuit? Please reference the Terms of Use and the Supplemental Terms for specific information related to your state. This is a collection of 22 possible affirmative defenses that may be used to defend a foreclosure action. Assn v. J.P. Morgan Mortg. Each new default, based on a different act or date of default, creates a new cause of action. Here, plaintiff failed to provide such notice. Some of the applicable programs here include the Federal Truth In Lending (TILA), which allows for recission, as well as: Home Ownership Equity Protection Act (HOEPA): Here, if the first mortgage lien has a high interest rate (the threshold amount varies depending on the loan amount) then it is a high rate loan covered by HOEPA. 3d 1176, 1179 (Fla. 2d DCA 2010) (Because J.P. Morgan did not own or possess the note and mortgage when it filed its lawsuit, it lacked standing to maintain the foreclosure action.). For instance, if the facts show that there was reliance by the mortgagor on statements of acts of the mortgagee relative to the mortgage relationship, then there will not be a valid acceleration of the debt under equitable principles of estoppel and waiver. InFlorida, residents who live in a planned development and who do not pay the required fees/assessments required by the HOA are exposed to the risk of home foreclosure. 2d 721 (Fla. Dist. There were a total of 12 affirmative defenses made against the plaintiffs claim. Box 23028, Tampa, FL 33623, and faxed [239-261-3659], and mailed Ashley D. Lupo, Esq., Roetzel & Andress, LPA, 850 Park Shore Dr., Fl 3, Naples, FL 34103. Then please feel free to send Larry an. Empire State Legal Forms However, a homeowner should know that Florida foreclosure law is constantly evolving resulting in some defenses no longer being available or some becoming more difficult to assert. Do Not Sell or Share My Personal Information, Common Defenses Used to Fight a Home Foreclosure in Florida, New Florida Law That Can Help You Get A Hardship License Without An Administrative Hearing, Do Not Sell or Share My Personal Information. Sackrin & Tolchinsky, P.A. affirmative defenses fail to provide fair notice to [the plaintiff] as to the nature of the defenses."). ([T]he statute of limitations on the balance under the note and mortgage would not continue to run after an involuntary dismissal, and thus the mortgagee would not be barred by the statute of limitations from filing a successive foreclosure action premised on a separate and distinct default.). defending against Florida causes of action that we routinely litigate. FAILURE TO COMPLY WITH APPLICABLE HUD SINGLE FAMILY DEFAULT LOAN SERVICES REQUIREMENTS/FAILURE TO COMPLY WITH CONDITIONS PRECEDENT: FAILURE OF GOOD FAITH AND FAIR DEALING: UNFAIR AND UNACCEPTABLE LOAN SERVICING, One affirmative defense we can use for when the lender lost the note (from our. Phone: (305) 227-4030. 3d 58, 60 (Fla. 4th DCA 2016) (Where there are conditions precedent to filing the suit, [a] plaintiff must also prove that it has complied with them.). Inc. v. Scialabba, 238 So. In the context of foreclosure lawsuits, the plaintiff will have unclean hands if it uses unscrupulous practices, overreaching, concealment, trickery, or other unconscientious conduct. Shahar v. Green Tree Servicing LLC, 125 So. In increasing numbers, homeowners have filed answers to foreclosure complaints, thus delaying, and in some instances, stopping judgments from being entered. 1957). Although the specific requirements vary in each loan agreement, lenders are usually required to provide borrowers with notice that they are behind in their loan payments, an opportunity to cure the default by making a payment or performing some sort of action within a stated period of time (usually not less than 30 days), and notice that if they do not cure the default in the stated period of time, the lender has the right to accelerate the loan. F.S. WHEREFORE, Defendants, De.O and Do.O, respectfully request that this Court take jurisdiction of the case, dismiss the Plaintiffs complaint with prejudice, decline to enforce the notice pled, award costs and reasonable attorneys fees to the Defendants and grant such further relief as this court deems just and proper. In this article, we provide a guide on how to defend against HOA foreclosure in Florida. Lets say your friend lets you borrow $20.00. Attorney for Defendants FAILURE TO COMPLY WITH APPLICABLE HUD SINGLE FAMILY DEFAULT LOAN SERVICES REQUIREMENTS/FAILURE TO COMPLY WITH CONDITIONS PRECEDENT: 9. 1987), appeal after remand, 526 So.2d 772 (Fla. 3d DCA 1988). In a foreclosure action, the bank must follow all the legal formalities of any other civil plaintiff. Most mortgages include a condition that the bank notify the homeowner that the loan is in default prior to initiating a foreclosure lawsuit. Notably, the "show me the note" and "lack of standing" defenses, while still effective, have been watered down some state court decisions. . If the bank fails to meet that legal notice requirement, then the defendant can request that the foreclosure action be dismissed. You are saying since the lender did not include an endorsement from the original lender, they have not proven the debt is actually owed to them. The notice to the homeowner must indicate the action required to cure the default and provide at least 30 days to cure the default before the bank can initiate foreclosure. The Plaintiff does not prove that it owns, holds, or has the right to enforce the mortgage. 2. We will present the elements of the actions; and suggest potentially successful defenses* to those actions. Using Affirmative Defenses When Answering A Foreclosure Complaint The home loan industry is heavily regulated, and many different federal laws have been passed by Congress not only to help borrowers get home loans but to oversee the actions of mortgage lenders. Anyproperty liensor attempts to foreclosure resulting from an unauthorized charge are not valid and cannot be enforced by an HOA against the propertys owner. Loan Tr. Affirmative Defenses to Foreclosure Lawsuits in Florida - EzineArticles Adam Smith Enterprises, Inc. v. Barnes, 539 So.2d 549 (Fla. 2d DCA 1989). For example, if a homeowner doesnt raise an affirmative in their answer and thereafter asserts it in response to a summary judgment motion brought by the bank then the homeowner may not be able to raise the defense at the hearing (however, a homeowner can always seek to amend their answer to raise an affirmative defense but dont wait until the hearing to do so). We recommend and urge you to consult with an experienced lawyer for professional advice as each case is unique. The specific requirements that lenders must follow to provide a borrower with notice of default are found in the loan documents or loan modification agreement. 1. 22 Affirmative Defenses To Stop Foreclosure - FRAUD STOPPERS Standing requires that the party prosecuting the action have a sufficient stake in the outcome and that the party bringing the claim be recognized in the law as being a real party in interest entitled to bring the claim. All other provisions ofFlorida Rule of Procedure 1.115must also be met, as the specific procedural rule governing mortgage foreclosures in Florida. Besides, the HOA also can record the lien with the county recorder to provide public notice that the claim exists (although there is no specific requirement for it). Also, please note, under Florida Statute 95.031, the SOL starts to run when the last element constituting the cause of action occurs. Standing requires that the party prosecuting the action have a sufficient stake in the outcome and that the party bringing the claim be recognized in the law as being a real party in interest entitled to bring the claim. - We Help Stop Home Foreclosure and Remove Debt Liability-. foreclosure costs, late charges, advances, and expenses incurred by the Plaintiff as a result of the default. However, if the foreclosing party is not the original lender, it must prove that it is the holder of the note and mortgage at the time of filing the foreclosure lawsuit and throughout the lawsuit, by submitting a note with a black or special endorsement, an assignment of the note, or an affidavit otherwise proving the plaintiffs status as the holder of the note. Defendants claims Plaintiffs non-compliance with the conditions precedent to foreclosure imposed on the plaintiff pursuant to applicable pooling and servicing agreement. IN THE CIRCUIT COURT OF THE The only evidence which purports to transfer any rights to the Mortgage and Note, is the endorsement listed on the copy of the note produced by Plaintiff. Plaintiff's actions, millions of homes have been foreclosed on or are in foreclosure. Above is only one part of the first affirmative defense but I will break down what it is saying piece by piece. Country Place Cmty. Kumar sued Nopal (the carrier) to recover the monetary loss of the stolen items. plaintiff allegations as to the ownership of the mortgage, plaintiffs authority to action behalf of the owner. By__________________________________________ Another defense in foreclosure lawsuits is that the foreclosing plaintiff came to the court with unclean hands. Reply - TO AMENDED AFFIRMATIVE DEFENSES AND MOTION TO STRIKEParty Affirmative Defenses Under Florida Law Gulisano Law, PLLC Charles B. Jimerson Typically you will reference previously ruled court cases to help your defense. Foreclosure Defense: Foreclosure Summary Judgment Plaintiff was not the owner/holder of the note and mortgage at the time the lawsuit initiated and it has no standing to bring this action. Under Florida law, statutes have been passed that contain very specific provisions on how the bank must give formal notice of default on the home loan. 2d 556, 57 (Fla. 4th DCA 1984) (quoting Shields v. Barrow, 58 U.S. (17 How.) If a bank cannot establish standing they will not be able to prevail in the foreclosure action. Neither the exhibits attached to Plaintiffs Complaint nor the allegations of the Complaint are sufficient to demonstrate standing. These articles are for informational purposes only and should not be relied upon as legal advice. Determine If Your Home Foreclosure is Eligible to be Defended. If the lender proceeds to file a foreclosure lawsuit, the borrower can raise this fact as an equitable estoppel defense if 1) he or she raises the defense in its answer and 2) can prove to the court that the bank has accepted the late payments. A good foreclosure attorney will find problems with the lenders foreclosure lawsuit and exploit them to your advantage. Ct. App. Standing means that the party seeking foreclosure has a right to bring the lawsuit. 1692(e)(5), (e)(10). Hence, all associated homeowners need to pay monthly fees (dues) and assessments to the HOA, an acronym for homeowners association, as a way to cover all costs. Bank Fails to Follow State And Federal Law Covering Home Loans. al., 462 So.2d 1178, (FLA. 3d DCA 1985). Under contractual law, any ambiguities shall be construed against the drafter, which in this case would be an interpretation against the Plaintiff and in favor of the defendant. PNC Bank, Natl Assn v. Smith, 225 So. Motion to File Amended Answer Foreclosure - HallandaleLaw.com The Homeowners went to the lender for the purpose of refinancing two In Florida, foreclosure defenses (for residential foreclosures) can be categorized into three different arguments. UnderFlorida Statute 95.11(2)(c), all mortgage foreclosure lawsuits must be filed within five (5) years. ("FDCPA") and Florida Consumer Collections Practices Act ("FCCPA"). FAILURE TO SATISFY CONDITIONS PRECEDENT. A successful fraud defense allows the homeowner to obtain rescission of the mortgage or alternatively, affirm the deal and ask for money damages. ANSWER: Mrs. Dunn admits that the mortgage is in default . In addition to providing an affirmative defense to lien foreclosure actions, fraudulent lien claims may, under 713.31(2)(c), be asserted as counterclaims, crossclaims, or . See, e.g.,Adam Smith Enterprises, Inc. v. Barnes, 539 So.2d 549 (Fla. 2d DCA 1989). STANLEY ABS CAPITAL I, INC., TRUST 1987), appeal after remand, 526 So.2d 772 (Fla. 3d DCA 1988). Your friend has a standing claim to the $20.00 that you owe him, meaning your friend is owed the money by you. Regardless of the situation, a lien must be properly recorded in the county records to be considered valid. 3. %PDF-1.3 If the loan document provides that lenders must provide borrowers with a notice of default, the lender must prove that it complied with these requirements before filing their foreclosure complaint. On or about August 21, 2000, DEFENDANTS INTERNATIONAL COLLECTION . Affirmative Defenses to plaintiffs Complaint, and in support thereof states the following: Defendants expressly, directly and explicitly deny any right to foreclose in its. : 2011-0793-CA-O. These defenses include issues like fraud, the statute of limitations, cancellation, release, incorrect legal description, among others. We are applying the same concept to this affirmative defense. To combat against a standing defense, lenders, or the holder of the note and mortgage, must ensure that it has proof of standing by demonstrating that it is the holder of the note and mortgage at the time of filing a foreclosure lawsuit and throughout the lawsuit. Defenses to an HOA Foreclosure in Florida - Loan Lawyers Do you have questions or comments? Copyright 2023 MH Sub I, LLC dba Nolo Self-help services may not be permitted in all states. Foreclosure defense forms must be drafted to comply with the laws of your State. ALAN D. SACKRIN, ESQ. Drafting an affirmative defense is a bit more complicated because you need to be very specific as to why they are wrong to try and foreclose on you. IN AND FOR ORANGE COUNTY, FLORIDA . attached to plaintiffs complaint as Exhibits. 130, 139 (1855)), where it defined an indispensable party as one whose interest in the controversy is of :such a nature that a final decree cannot be made without either affecting that interest, or leaving the controversy in such a condition that its final termination may be wholly inconsistent with equity and good conscience. Although MERS, as original mortgagee, is an indispensable party, Plaintiff did not join MERS in this action. Similarly, in some instances, there have been so many assignments (and the assignments were handled so carelessly) that the original notes are missing. In Florida, lack of standing is a common defense in a foreclosure lawsuit. The third category of foreclosure defenses is similar to the arguments against the legality of the default. To understand how this helps our case here is a quick background on the ruling: Seller: Kumar <- Doing the suing, Buyer: Nava <- Legally should be doing the suing instead of Kumar. Although this blog does not contain all of the possible defenses a borrower may raise in a foreclosure lawsuit, it contains some of the most common defenses. The best way for lenders to succeed in their foreclosure lawsuit is to ensure the borrower cannot succeed on possible defenses. Defendant. For more, readOcwen Filing Bad Foreclosure Lawsuits: Is Ocwen Servicing Your Mortgage? Track Case Changes Download Document Print Document On January 13, 2014 a Real Prop Comm Foreclosure =/>$250,000 case was filed . If the loan servicer failed to properly credit payments and/ or charge costs in compliance with this statute the lender may have a problem prevailing in the foreclosure action. 2006-HE6, MORTGAGE PASS-THROUGH If the mortgage has changed hands between financial institutions (one bank sells the loan to another), then there needs to be proper corresponding assignments of the mortgage and endorsements to the note (or the Allonge). The attorney listings on this site are paid attorney advertising. Based on this, a lender, or the holder of the note and mortgage, must bring its foreclosure lawsuit within five years from the date of default. Kumar had not received payment from Nava and was not carrying insurance for the items being sold. What Exposure Does a Business Have to Attorneys Fees Under the FCCPA and the FDCPA? Many state legislatures have enacted mandatory notice requirements that lenders are required to follow prior to commencing a mortgage foreclosure proceeding. % Standardized forms for all States are generally not acceptable. There are times when the borrower has paid his or her monthly mortgage payments late, but the lender still accepts the payments. Some of the law firms that handled the largest volume of foreclosures several years ago have been forced out of business. 1. Shahar v. Green Tree | Fla. 4th DCA - Unclean Hands Doctrine 4 0 obj 3d 317, 319 (Fla. 4th DCA 2018) (Giving a notice of default is a condition precedent to foreclosure in most residential mortgages.). Fla. Stat. FAILURE OF GOOD FAITH AND FAIR DEALING: UNFAIR AND UNACCEPTABLE LOAN SERVICING. 1. Based on this, lenders, or the holder of the note and mortgage, should be sure to review the loan documents and provide borrowers with the required notice of default before filing a foreclosure lawsuit, or risk having the foreclosure lawsuit dismissed. The ruling of Kumar Corp. v Nopal Lines reinforces your argument. Failure to prove standing at the time of filing the foreclosure lawsuit will result in the foreclosure lawsuit being dismissed. Answer & Affirmative Defenses - TO PLAINTIFF'S COMPLAINT/MARLON WALTERS Sample Affirmative Defenses and counterclaim - Free download as Word Doc (.doc), PDF File (.pdf), Text File (.txt) or read online for free. Some of the common defenses used to fight foreclosure are described below. Discussion: 3.03 3.03[2] Necessity of Pleading the Defense. LARRY TOLCHINSKY, ESQ. PDF DEFENDANT - The Florida Bar Some of the common defenses to foreclosure include: lack of standing; failure to provide required notice of default; statute of limitations; and unclean hands. This person has legal duties underRule 1.070and the Florida Statutes, including Florida Statutes48.20,48.031(5). See, e.g., our past success using this foreclosure defense against Bank of America in Florida Foreclosure Appeal on The Issue of Standing; Victory Against Bank of America.. See, e.g.,Rashid v. Newberry Fed. All forms are available in Word format. DEFENDANT'S AMENDED ANSWER AND AFFIRMATIVE DEFENSES TO VERIFIED COMPLAINT FOR FORECLOSURE OF MORTGAGE AND DEFENDANT'S COUNTERCLAIMS AND ADDITIONAL PARTY CLAIMS The Defendant, by and through her undersigned counsel hereby files this Amended Answer and Affirmative Defenses in response to Plaintiff's Complaint for Foreclosure of For more, read Payment Defense to Foreclosure. This would be a feasible defense if the lender plainly states that they are unable to produce the note. Defendants hereby claim and reserve any right or interest it may have in or to any surplus proceeds that may result from the Plaintiffs foreclosure of the subject property. Usually, mortgage lenders are required by the loan documents to give borrowers notice of default as a condition precedent to bring a foreclosure lawsuit. Potential Defenses Against HOA Foreclosure in Florida When an HOA Is Not Authorized by CC&Rs to Foreclose Commonly, any CC&R governing an HOA must contain certain provisions to provide how. 1:12-cv-01963 (Northern District of Illinois 2012) . To increase chances of success in foreclosure, lenders should be aware of what these defenses are and how to overcome them. UIC Law Open Access Repository For instance, there is a 30-day notice of default that must be given before the bank starts the foreclosure process. For example, in a foreclosure complaint the plaintiff will charge that you haven't been paying your mortgage and they're entitled to foreclose because of that. Based on this, a lender, or the holder of the note and mortgage, must ensure that it is coming to the court with clean hands. Home/14 colony lane, bratenahl/ sample foreclosure affirmative defenses florida. The failure to follow any of these federal laws, rules, or regulations by the mortgage lender can become a valid federal statutory foreclosure defense for the borrower in a Florida foreclosure lawsuit. They should have an. 57.105 and the. 2d 488 (Fla. Dist. 1971). Co., 159 So. by Larry Tolchinsky | Florida Foreclosures, Foreclosure Defense | 0 comments. P. 1.110 are not addressed here, but should However, there are others including, incorrect legal description in the mortgage (there is case law here), estoppel, unclean hands, and rescission. Was There A Legal Right To Accelerate The Debt? Bank Failed to Provide Proper Legal Notice to Borrower. A homeowner can tender payment to the bank as a way of defending against a Florida foreclosure lawsuit. Under 12 CFR 226.3, a buyer or assignee must notify the borrower within 30 days from the date a mortgage loan is sold or assigned to a new owner. Even though receiving a notice that an HOA began a foreclosure against you is not a positive thing, the ideal approach is to stay calm and not waste time with uncertainty. A bank seeking to foreclose a home in Florida must provide evidence that it owns or holds the promissory note and mortgage to prove standing. Kumar Corp. v Nopal Lines, Ltd was a court case that was ruled in back in 1985. In a substantial number of cases, foreclosing plaintiffs (who are typically assignees, rather than the original lenders) are unable to produce the alleged assignment documents pursuant to which they purportedly acquired an interest in the loan. Further, the list of defenses described above is not exhaustive, there may be many other legal defenses available. To increase chances of success in foreclosure, lenders should be aware of what these defenses are and how to overcome them. How can it help me stop foreclosure? CERTIFICATES, SERIES 2006-HE6, 559.72, et. Each one of the affirmative defense will have a lengthy explanation as to what is wrong with the foreclosure summons and why. Affirmative Defenses to Include in Foreclosure Answers The Defendants, De.O and Do.O, assert the following affirmative defenses to Plaintiffs claim: 1. Contact us now Free Consultation. However, the information contained herein is relevant to the borrower and its counsel as well. In Criminal and Civil law, an Affirmative defense is a fact or set of facts that if proven by the defendant, nullifies or mitigates the legal consequences of the defendant's otherwise unlawful conduct. If either of these documents is not attached to the document, or if they are incomplete in any way, then the procedural rules have not been met. The "show me the note" and "lack of standing" defenses are usually available only to property owners who both: (a) answer the foreclosure summons and complaint, and (b) assert the defenses in their responses as affirmative defenses. denied and strict proof is demanded thereon. Foreclosure Answer and Affirmative Defenses | PDF - Scribd Some of the common defenses to foreclosure include: lack of standing; failure to provide required notice of default; statute of limitations; and unclean hands. mortgage and note, and other such relief that this court deems proper. The note which was attached to the original Complaint shows the Note being endorsed from the Original Lender to a SuperStar Mortgage Inc. In order to establish unclean hands, the homeowner must show either a fraudulent or illegal transaction or any unrighteous, unconscious, or oppressive conduct by the party seeking foreclosure. If these documents are not correct, or not provided, then the borrower has specific legal remedies as defined in the statute. Several potential defenses can be utilized in cases involving HOA foreclosure, including cases in which: Other common defenses include situations in which the CC&Rs do not authorize the HOAs charges or do not authorize the HOA to foreclose a property. Seek help with anexpert foreclosure attorneyto find a defense strategy for your case. The amount due can vary depending on if the bank has filed foreclosure (thus, incurring attorney fees, costs, and additional interest expenses) or if it has accelerated the loan. Corp. v. TSE Plantation, LLC, 301 So. There are more issues that can be raised to defend a Florida foreclosure lawsuit, like usury and duress. 731, 731 (Fla. 1904) (syllabus). Bartram v. U.S. Bank Nat. 4. Kumar Corp. v Norpal Lines, Ltd, et. 20TH JUDICIAL CIRCUIT IN AND That was just one case ruling example. See, Florida Rules of Procedure 1.115(e). Otherwise, the court might decide the charges are not valid. COMPANY, AS TRUSTEE FOR MORGAN CASE NO: 07-xxxx-CA Defenses based on missing mortgage documents and/or assignments are far from the only defense tactics available to foreclosure defendants. The defense of unclean hands is an equitable defense, however, [a]ll mortgages in Florida are foreclosed in equity. Fla. Stat. 2100 East Hallandale Beach Blvd./Suite 200 IT IS HEREBY CERTIFIED that on October 14, 2011, a true and correct copy of the foregoing was faxed [813-221-9171], and mailed to Ryan Weeks, Esq., Albertelli Law, P.O. We recommend and urge you to consult with an experienced lawyer for professional advice as each case is unique. x%9)&s`]_g=^,zjlguDQ$EOo{miog{?/ooO])k[P*%t{%kX?gd7q?~MmW?l{,?g9gAr-~G~?m-?U~i{mgoKWr:enX>Z3d.1,o/6(K[)+dn~c=tmYlO)n~\5+&96iY#go{,pXj9kYZo}{vy%C}ZD}txopv R2R2i3Fox{`Cg?}=#%L|=~_kmL~zkKYcou2trijln5Yi:&.};j{nO\h5:tg23d>IP%*vBx. Nopal argued that Kumar, Drafting an affirmative defense is a bit more complicated because you need to be. Shahar, 125 So. Notably, financial institutions have also been proactive and creative in crafting legal arguments to overcome such affirmative defenses. And if the HOA begins a foreclosure, don't panic; you might have a defense to the action, like: the HOA charged you too much or charged you unreasonable fees. To begin, there is nothing attached to the Complaint which establishes that Plaintiff, WELLS BANKER, AS SUCCESSOR TRUSTEE UNDER SUPERSTAR MORTGAGE FUNDING TRUST, SERIES 2010-2, possessed the requisite legal standing at the inception of this foreclosure action. Oftentimes, borrowers engage in technical defaults, like quit claiming an interest in the property to a family member, or they make late payments. Standing is important because it is what the lender should have in order to foreclose. The notice required under this statute must be sent to the homeowner within 30 days of the assignment. stream In verified form, the Homeowners specifically alleged the following to have expressly occurred throughout the course of the loan process. Nopal argued that Kumar did not have standing to sue because there is a Florida statue that says the risk of loss or damage as passed to the buyer (Nava) after items are sold. Florida is a judicial foreclosure state, which means that the bank must go to court and receive court approval before foreclosing on a home. A homeowner should consider asserting, as an affirmative defense to foreclosure, that the foreclosing plaintiff has not complied with its statutory notice obligations. This is a sample document related to a specific set of facts and circumstances and should not be used or relied upon if any foreclosure, deficiency judgment, short sale or any other real estate matter. Amended Answer and Affirmative Defenses - Foreclosure vs. allegations are expressly, directly and explicitly denied and strict proof is, paragraph, therefore the allegations are exp. The Defendants, De.O and Do.O, by and through undersigned counsel, file this Amended Answer and Affirmative defenses against the Plaintiff, DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR MORGAN STANLEY ABS CAPITALI, INC., TRUST 2006-HE6, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-HE6, and state as follows:
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