Actions to foreclose on a mortgage are governed by a six-year statute of limitations, pursuant to CPLR 213[4]. When the mortgage is payable in installments, as is the typical practice, an acceleration of the entire amount due begins the running of the statute of limitations on the entire debt. However, a party purporting to accelerate the debt must establish standing by demonstrating that, at the time the action was commenced, it was either the holder or an assignee of the underlying note.
Deutsche Bank Trust Co. Ams. v. Marous, NY Slip Op 04536 (2d Dep't August 19, 2020)
