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

Conn. Gen. Stat. § 47-20 (2025)

Use of word “trustee” or “agent” in an instrument affecting real estate

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The word “trustee” or “agent”, or the words “as trustee”, or words of similar meaning, following the name of the grantee in a duly executed and recorded instrument which conveys, transfers or assigns real estate or any interest therein, with or without the name of a cestui que trust or principal appearing and without any other language expressly limiting the powers, interest or estate of the grantee, do not, in the absence of a separate duly executed and recorded instrument defining the powers of the grantee, affect the right of the grantee to sell, mortgage or otherwise dispose of the real estate or interest therein in the same manner as if those words had not been used. No person to whom such real estate or interest therein has been transferred or mortgaged by such grantee is liable for the claim of any undisclosed beneficiary or principal or for the application of any money which may have been paid by such person therefor.

(1949 Rev., S. 7103; 1969, P.A. 6; P.A. 79-602, S. 8.)

History: 1969 act added references to “agent” and “mortgage” action; P.A. 79-602 restated provisions but made no substantive changes.

Use of term “trustee” held to be a nullity. 147 C. 451. Section protects only the interests of third parties who obtain property by means of conveyance from a grantor who had received that property as trustee in the first instance and does not apply where conveyance to third-party grantee did not occur. 324 C. 277.

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Notes of Decisions
Cited in 11 cases (3 in the last 5 years), 1960–2024 · leading case: Lackman v. McAnulty, 151 A.3d 1271 (Conn. 2016).
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Lackman v. McAnulty, 151 A.3d 1271 (Conn. 2016). · cites it 42× “In this case, we consider whether a grantor's failure to record a separate document limiting his powers " 'as trustee' " in accordance with General Statutes § 47-20, 1 when that grantor quitclaimed real property to himself as trustee, has the effect of nullifying the transfer of…”
Verspyck v. Franco, 874 A.2d 249 (Conn. 2005). · cites it 3× “General Statutes § 47-20 provides in relevant part: “The word ‘trustee’ .”
Verspyck v. Franco, 884 A.2d 432 (Conn. App. Ct. 2005). · cites it 5× “Its decision was based on General Statutes § 47-20, which has recordation requirements with which the trust had not complied.”
Verspyck v. Franco, 841 A.2d 267 (Conn. App. Ct. 2004). · cites it 9× “It dismissed the defendant’s complaint because the trust had not availed itself of the opportunity of recordation pursuant to General Statutes § 47-20. 3 The United States Court of Appeals for the Second Circuit affirmed summarily.”
Benassi v. Harris, 162 A.2d 521 (Conn. 1960). · cites it 2× “The use of the word “trustee” was a nullity; General Statutes § 47-20 ; and could not make Harris ipso facto a trustee.”
First Union Nat'l Bank v. Lindley Labs., Inc., 510 S.E.2d 187 (N.C. Ct. App. 1999). “C.G.S. § 47-20 (Supp. 1997). Because subrogation cannot be used to displace Defendant’s “intervening right of title,” the trial court correctly denied Bank any declaratory relief.”
Cooper v. Mortg. Investors Corp. (In re Kline), 242 B.R. 306 (Bankr. W.D.N.C. 1999). · cites it 2× “C.G.S. § 47-20 et. seq., are satisfied to avoid Mortgage Investors’ deed of trust.”
Reynolds-Douglass v. Terhark, 873 S.E.2d 552 (N.C. 2022). “Therefore, the proper calculation of attorney’s fees would be: $2,500 (earnest money deposit) x 15% (statutory rate) = $375 (in attorney’s fees).”
CL Howard Invs. I, LLC v. Wilmington Sav. Fund Soc'y, 911 S.E.2d 384 (N.C. Ct. App. 2024). · cites it 3× “C.G.S. § 47-20, a senior deed of trust loses its priority to a junior deed of trust when the senior deed of trust is modified via a loan modification to extend the maturity date and filed at a date later than the junior deed of trust’s initial filing date.”
Reynolds-Douglass v. Terhark, 873 S.E.2d 552 (N.C. 2022). “Therefore, the proper calculation of attorney’s fees would be: $2,500 (earnest money deposit) x 15% (statutory rate) = $375 (in attorney’s fees).”
Hartford Elec. Light Co. v. Reale, 432 A.2d 1194 (Conn. Super. Ct. 1981). · cites it 2× “General Statutes § 47-20 provided: “The word ‘trustee’ .”
Conn. Gen. Stat. § 47-20(d): 2 cases
Reynolds-Douglass v. Terhark, 873 S.E.2d 552 (N.C. 2022). “Therefore, the proper calculation of attorney’s fees would be: $2,500 (earnest money deposit) x 15% (statutory rate) = $375 (in attorney’s fees).”
Reynolds-Douglass v. Terhark, 873 S.E.2d 552 (N.C. 2022). “Therefore, the proper calculation of attorney’s fees would be: $2,500 (earnest money deposit) x 15% (statutory rate) = $375 (in attorney’s fees).”
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