Conn. Gen. Stat. » Title 47 — LAND AND LAND TITLES · Chapter 821 — Land Titles
Connecticut General Statutes

Conn. Gen. Stat. § 47-10 (2026)

Conveyance to be recorded. Recorded conveyance not invalid or unenforceable if original documentation converted into digital or electronic form, lost or destroyed

✓ current as of May 2026
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(a) No conveyance shall be effectual to hold any land against any other person but the grantor and his heirs, unless recorded on the records of the town in which the land lies. When a conveyance is executed by a power of attorney, the power of attorney shall be recorded with the deed, unless it has already been recorded in the records of the town in which the land lies and reference to the power of attorney is made in the deed.

(b) Any conveyance that is otherwise effective and properly recorded before, on or after October 1, 2002, in accordance with subsection (a) of this section shall not be invalid or unenforceable because the original documentation evidencing such conveyance is converted into digital or electronic form or is lost or destroyed at any time after such recordation.

(1949 Rev., S. 7091; P.A. 79-602, S. 35; P.A. 02-66, S. 1.)

History: P.A. 79-602 restated provisions but made no substantive change; P.A. 02-66 designated existing provisions as Subsec. (a) and added Subsec. (b) re properly recorded conveyance not invalid or unenforceable if original documentation evidencing conveyance is converted into digital or electronic form or is lost or destroyed.

See Secs. 7-35aa to 7-35gg, inclusive, re Uniform Real Property Electronic Recording Act.

When and how delay to record at length affects title of grantee. K. 72; 1 R. 61, 81, 500; 2 R. 287, 298. When parol evidence admissible to show actual time of recording. 1 R. 81. Rule that deed first recorded obtains priority; how qualified. 2 R. 239, 383; 2 C. 467; 4 C. 575; 8 C. 342; 15 C. 307; 71 C. 100. Action lies against clerk for delivering up deed before recording. 2 R. 85. Bona fide later purchaser without notice of former conveyance by unrecorded deed holds against such former purchaser. Id., 420. Whether a deed releasing an equity of redemption is valid without being recorded. 2 D. 280. Unrecorded deed not good against disseizor. 2 C. 92. What writing is not required to be recorded. Id., 467. What notice of encumbrance the condition of a mortgage deed must give; 4 C. 158; 5 C. 442; 6 C. 37, 116; 7 C. 387; 8 C. 215; 9 C. 286; 12 C. 195; 13 C. 165, 376; 14 C. 77; 15 C. 562; 16 C. 260; 18 C. 257; 19 C. 29; 20 C. 240, 427, 603; 31 C. 74, 488; 46 C. 313; 73 C. 318; 74 C. 198; Id., 405; 76 C. 388; 84 C. 329; 85 C. 46; 91 C. 496; U.S. Supreme Court follows rule of state court. 91 U.S. 452. Return to grantor and cancellation of unrecorded deed does not divest grantee's title. 4 C. 550; 5 C. 262. Covenant of seizin may be broken, although grantee by first recording has secured title. Id. Recording of deed, defective in a statute requisite does not give notice. Id., 468; 8 C. 549; 14 C. 135; 87 C. 369. When unrecorded deed admissible in evidence. 7 C. 291. Action lies for fraudulent withdrawal of deed from clerk's office. 8 C. 342. Mortgage deed recorded after death of mortgagor, good. 11 C. 174. Estate by curtesy cannot be divested by disclaimer duly signed, attested, acknowledged and recorded. 13 C. 83. What record of power of attorney sufficient. 14 C. 32. Burden of proof rests on prior grantee who claims against subsequent deed first recorded. 17 C. 594. When conveyances may be proved by copies of records. 18 C. 311. Deed not recorded until after death of grantor good against a purchaser from his heir at law. 24 C. 211. Deed defective in formal requisite is treated in a court of equity as an executory contract for sale of land. 27 C. 104. What is a reasonable time in which to record deed. 40 C. 85. A mortgage not recorded until after attachment of the mortgaged property, where the delay is unreasonable and unexplained, is not good against the attaching creditor. Id., 214. Placing a deed on record with intent to pass title to grantee makes a legal delivery. 49 C. 570. Party lending on mortgage in good faith is not charged with notice of equities which do not appear of record. 50 C. 46. Question of priority between deed with covenants given before grantor acquired title and deed given, after title acquired, to purchaser in good faith, for value, without notice. Id., 113. Casual knowledge of prior unrecorded mortgage does not charge notice thereof against party taking second mortgage on same land 9 years later. Id., 517. Absolute recorded deed, with separate unrecorded defeasance, making it a mortgage, is invalid against grantor's attaching creditor. 51 C. 446. Provision in railroad company's charter may render unnecessary recording conveyance of its property in land records. 52 C. 274. Grantee not affected by mistake in recording his deed; various points about priority of mortgages. 56 C. 55. Failure to discover record, no defense. 68 C. 305. Notice of building restriction by record. Id., 367. Title of trustee in insolvency takes precedence of prior mortgages unrecorded for two years. 71 C. 358. Priorities between purchaser of land and execution creditor; 70 C. 356; between attaching creditor and purchaser failing to record deed. 71 C. 364; 91 C. 423. What is reasonable time for record, question of fact; 71 C. 95; 91 C. 423; when properly recorded, deed dates back to time of delivery. 76 C. 44; 91 C. 423. Policy of our law is to show title by record; 74 C. 405; 84 C. 329; 85 C. 47; 87 C. 99; 108 C. 24; mortgage; 82 C. 306. Withholding record of mortgage to uphold mortgagor's credit is fraudulent. 74 C. 367. Extent of notice by record. Id., 405; 76 C. 50; 80 C. 329; 102 C. 687. Priority where A, having no title, deeds land to B, then gets title and deeds to C. 76 C. 44. Deed endorsed as recorded after mortgage back, held to precede mortgage. Id., 47. Effect of knowledge of right not appearing of record. 83 C. 581; 87 C. 90; Id., 209. Effect of failure to record separate defeasance. 85 C. 46; 89 C. 444. Creditor's rights where deed or mortgage is not recorded. 85 C. 46; Id., 696. Priority where one purchases after mechanic's lien attaches but before record. 87 C. 316. Unrecorded deed; how far good. 89 C. 35, 45. Recording mortgage of street railway. Id., 63. Only creditor who extends credit on strength of record title can prevail over undisclosed equitable rights of third parties. 91 C. 576. Mortgagee without notice and giving value may foreclose regardless of such equities. Id., 580. That land records would have shown true title is no defense in action for fraudulent misrepresentation as to title. 94 C. 226. Distinction between constructive knowledge from land records as regards character and extent of actual title, and such knowledge in creating personal rights related to title. Id., 225. Recording of a map is inoperative unless clearly referred to in properly recorded deed. 108 C. 541. Cited. 109 C. 438; 113 C. 481. Assignment of a mortgage falls within statute. 121 C. 268. Prior assignee of mortgage who failed to record estopped by conduct; one invoking estoppel must exercise good faith and reasonable diligence. 126 C. 101. Mechanic's lien given priority over purchase money mortgage not recorded until after materials were furnished. 130 C. 367. Cited. 132 C. 554. Lack of actual notice of restrictions cannot aid defendant since they were on record. 138 C. 188. If a deed of real property is given to secure a debt, it must describe the indebtedness with reasonable accuracy to be valid against other encumbrances. 146 C. 523. Cited. 182 C. 1; 207 C. 555; 219 C. 810; 221 C. 77.

Cited. 5 CA 429; 31 CA 696; 33 CA 197; 35 CA 682; 41 CA 754. Section does not indicate that a flaw in the instrument or its recordation would make it inadmissible as evidence; when read together with Sec. 47-5, indicates that only when a natural person attempts to convey property through a power of attorney must the instrument creating the power be filed with the conveyance, or have been previously filed, to have legal effect. 51 CA 733. The dictates of Secs. 49-17 and 49-33 trump those in this section, and therefore a valid assignee of a mortgage note has standing to foreclose irrespective of whether that assignee records the assignment prior to instituting the action. 167 CA 183.

Unless a mortgage is recorded within a reasonable time before the execution of a subsequent mortgage, the latter has priority. 6 CS 97. Reasonable time depends upon the facts in each particular case. 11 CS 407. Cited. 15 CS 466. Quitclaim deed executed in 1936 and recorded in 1948 not good against a judgment lien recorded more than 5 months previously. 16 CS 428.

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Notes of Decisions
Cited in 32 cases (4 in the last 5 years), 1967–2025 · leading case: Astoria Fed. Mortg. Corp. v. Genesis Ltd. P'ship, 143 A.3d 1121 (Conn. App. Ct. 2016).
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Astoria Fed. Mortg. Corp. v. Genesis Ltd. P'ship, 143 A.3d 1121 (Conn. App. Ct. 2016). · cites it 17× “We address the defendant's claim that the court erred in granting the plaintiff's motion to dismiss because it improperly concluded that the defendant lacked standing as a result of its failure to record, prior to filing its cross claim, the October 12, 2012 assignment of the…”
Fam. Fin. Servs., Inc. v. Spencer, 677 A.2d 479 (Conn. App. Ct. 1996). · cites it 10× “The plaintiff and the Masottas claim that General Statutes § 47-10 does not apply to mortgages.”
Webster Bank v. Flanagan, 725 A.2d 975 (Conn. App. Ct. 1999). · cites it 4× “General Statutes § 47-10 provides: “No conveyance shall be effectual to hold any land against any other person but the grantor or his heirs, unless recorded on the records of the town in which the land lies.”
Farmers & Mechanics Sav. Bank v. Garofalo, 595 A.2d 341 (Conn. 1991). · cites it 5× “Lyon & Billard maintains that § 52-285 should be interpreted to afford to judicial liens the same treatment as that afforded to recorded mortgage deeds pursuant to General Statutes § 47-10 5 *816 and to recorded mechanic’s liens pursuant to General Statutes §§ 49-34 6 and 49-33…”
Nash v. Stevens, 71 A.3d 635 (Conn. App. Ct. 2013). · cites it 6× “To read § 47-33a to exclude terms that were included in the agreement because they were not included in the recorded deed would improperly impose a recording requirement that is not in the statute.”
Connecticut Nat'l Bank v. Lorenzato, 602 A.2d 959 (Conn. 1992). · cites it 5× “General Statutes § 47-10 provides, in relevant part: “No conveyance shall be effec *81 tual to hold any land against any other person but the grantor and his heirs, unless recorded on the records of the town in which the land lies.”
Lettieri v. Am. Sav. Bank, 437 A.2d 822 (Conn. 1980). · cites it 2× “General Statutes § 47-10. The plaintiffs have not appealed the judgment rendered against them on this count.”
Geiger v. Carey, 154 A.3d 1093 (Conn. App. Ct. 2017). · cites it 2× “Under General Statutes § 47-10, while an unrecorded deed is effective between the parties to the deed, the failure to record the deed renders it ineffective against other parties.”
Matter of Sansone, 126 B.R. 16 (Bankr. D. Conn. 1991). · cites it 4× “Fleet responds that by receiving validly-executed mortgages and assignments of rents and recording them pursuant to Conn.Gen.Stat. § 47-10, 1 it held fully perfected interests in the rents on the date of the filing of the debtor’s bankruptcy petition.”
Fed. Nat'l Mortg. Ass'n v. Buhl, 201 A.3d 485 (Conn. App. Ct. 2018). · cites it 2× “See General Statutes § 47-10 ("[n]o conveyance shall be effectual to hold any land against any other person but the grantor and his heirs, unless recorded on the records of the town in which the land lies").”
Clean Corp. v. Foston, 634 A.2d 1200 (Conn. App. Ct. 1993). · cites it 2× “” General Statutes § 47-10 provides in pertinent part: “No conveyance shall be effectual to hold any land against any other person but the grantor and his heirs, unless recorded on the records of the town in which the land lies.”
Il Giardino, LLC v. Belle Haven Land Co., 757 A.2d 1103 (Conn. 2000). “in sections 47-33b to 47-331, inclusive: “(a) ‘Marketable record title’ means a title of record which operates to extinguish such interests and claims, existing prior to the effective date of the root of title, as are stat ed in section 47-33e; “(b) ‘Records’ means the land…”
Show all 32 citing cases →
— Conn. Gen. Stat. § 47-10(a) — 1 case
Astoria Fed. Mortg. Corp. v. Genesis Ltd. P'ship, 143 A.3d 1121 (Conn. App. Ct. 2016). “We address the defendant's claim that the court erred in granting the plaintiff's motion to dismiss because it improperly concluded that the defendant lacked standing as a result of its failure to record, prior to filing its cross claim, the October 12, 2012 assignment of the…”
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