Massachusetts General Laws

Mass. Gen. Laws ch. 244, § 20 (2026)

Accounting

✓ current as of July 2026

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Section 20. If the mortgagee or person claiming or holding under him has had possession of the land, he shall account for rents and profits, and be allowed for all amounts expended in reasonable repairs and improvements, for all lawful taxes and assessments paid and for all other necessary expenses in the care and management of the land. A balance of such account, if due from him, shall be deducted from the debt due on the mortgage; if due to him, shall be added to the debt, and paid or tendered as such.

Notes of Decisions

Cited in 5 cases, 1922–1974 · leading case: City Inst. for Sav. v. Kelil, 159 N.E. 731 (Mass. 1928).

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City Inst. for Sav. v. Kelil, 159 N.E. 731 (Mass. 1928). “It is provided by G. L. c. 244, § 20, that if a mortgagee, as in the case at bar, “has had possession of the land, he shall account for rents and profits, and be allowed for all amounts expended in reasonable repairs and improvements, for all lawful taxes and assessments paid…”

Strong v. Merchants Mut. Ins., 309 N.E.2d 510 (Mass. App. Ct. 1974). “The plaintiff also contends that he is entitled to damages because “the bank conducted its possession negligently in that it failed to comply with the requirements of G. L. c. 244, § 20 for an accounting.” We are of the opinion that § 20, which “appears under the subtitle…”

MacFarlane v. Thompson, 241 Mass. 486 (Mass. 1922). “G. L. c. 244, § 20. It would seem that the building of the cesspool was a reasonable repair and improvement within the meaning of the statute.”

Hadley Falls Trust Co. v. United States, 22 F. Supp. 346 (D. Mass. 1938). “It is provided by G.L. c. 244, § 20, that if a mortgagee, as in the case at bar, ‘has had possession of the land [then follows the remainder of section át), as quoted above].”

Rehrig v. Inman, 155 N.E. 455 (Mass. 1927). “The plaintiff, therefore, was entitled to a reconveyance upon paying such sum as might be found due on an accounting under G. L. c. 244, § 20. The facts found justified the conclusion that such expenditure as had been made upon the premises, although greater than ordinarily…”

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