The action is governed by a six-year statute of limitations, pursuant to CPLR 213[4]. Even if the mortgage is payable in installments, once the debt is accelerated, the entire amount is due and the statute of limitations begins to run on the entire debt. The commencement of the action accelerates the debt. The lender may revoke its election to accelerate the mortgage, but it must do so by an affirmative act of revocation occurring during the six-year statute of limitations period subsequent to the initiation of the foreclosure action.
Bank of N.Y. Mellon v. Conforti, NY Slip Op 05973 (2d Dep't October 26, 2022)
