In a rare win for mortgage lenders, the 11th Circuit ruled today that an owner who agrees to “surrender” their residence in bankruptcy court under 11 U.S.C. Section 521 also forfeits the right later to challenge any foreclosure proceedings on the property. The court affirmed a lower court decision in favor of Citibank NA , which was blocked from commencing foreclosure proceedings on a Florida couple's home after the two had surrendered the house to discharge their debt.

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