Mich. Comp. Laws » Michigan Compiled Laws / Chapter 600 / Act 236 of 1961
Michigan Compiled Laws

Mich. Comp. Laws § 600.3201 (2026)

Foreclosure by advertisement of mortgage containing power of sale; exception.

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REVISED JUDICATURE ACT OF 1961


Act 236 of 1961


600.3201 Foreclosure by advertisement of mortgage containing power of sale; exception.

Sec. 3201.

    Every mortgage of real estate, which contains a power of sale, upon default being made in any condition of such mortgage, may be foreclosed by advertisement, in the cases and in the manner specified in this chapter. However, the procedures set forth in this chapter shall not apply to mortgages of real estate held by the Michigan state housing development authority.

History: 1961, Act 236, Eff. Jan. 1, 1963 ;-- Am. 1981, Act 172, Imd. Eff. Dec. 10, 1981

Constitutionality Notes:

    Plaintiff's claim of unconstitutionality for MCL 600.3201 et seq. failed for lack of the existence of state action. Cramer v Metropolitan Savings and Loan Association, 401 Mich 252; 258 NW2d 20 (1977).

Notes of Decisions
Cited in 85 cases (11 in the last 5 years), 1974–2025 · leading case: Bank of Am. Na v. First Am. Title Ins. Co., 878 N.W.2d 816 (Mich. 2016).
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Bank of Am. Na v. First Am. Title Ins. Co., 878 N.W.2d 816 (Mich. 2016). · cites it 3× “2 MCL 600.3201 et seq. 3 Bank of America sold Enid for $632,500, Heron Ridge for $1,150,000, Golf Ridge for $325,000, and Kirkway for $440,000.”
Kim v. Jpmorgan Chase Bank, Na, 825 N.W.2d 329 (Mich. 2012). · cites it 2× “* * * (3) If the party foreclosing a mortgage by advertisement is not the original mortgagee, a record chain of title shall exist prior to the date of sale under [MCL 600.”
Est. of Darryl Houston Price v. Lori Jean Kosmalski, 821 N.W.2d 503 (Mich. 2012). · cites it 2× “See MCL 600.3201 through 600.3224. Upon that sale, the purchaser acquires a sheriff’s deed, which only becomes effective if the mortgagor does not exercise his or her right of redemption within the applicable statutory window.”
Senters v. Ottawa Sav. Bank, 503 N.W.2d 639 (Mich. 1993). · cites it 2× “6 MCL 600.3201; MSA 27A.3201. 7 See MCL 600.”
Cramer v. Metro. Sav. & Loan Assoc., 258 N.W.2d 20 (Mich. 1977). · cites it 3× “Plaintiff finally stopped the escrow payments, and stated that she wished to make her tax and insurance payments directly. Plaintiff admits in her brief that she did not maintain a current escrow account.”
Kubczak v. Chem. Bank & Trust Co., 575 N.W.2d 745 (Mich. 1998). · cites it 2× “§ 600.3201 et seq.; M.S.A. § 27A.3201 et seq.”
Residential Funding Co. v. Saurman, 490 Mich. 909 (Mich. Ct. App. 2011). · cites it 2× “Thereafter, MERS began nonjudicial foreclosures by advertisement as allegedly permitted under MCL 600.3201 et seq., purchased the property at the subsequent sheriffs sales, and then quitclaimed the property *327 to plaintiffs as respective successor lenders.”
Nat'l Airport Corp. v. Wayne Bank, 252 N.W.2d 519 (Mich. Ct. App. 1977). · cites it 3× “Plaintiff brought an action to enjoin the foreclosure by advertisement of property mortgaged to defendant, contending that the statutory procedure, MCLA 600.3201 et seq.; MSA 27A.3201 et °seq.”
In re Taj Graphics Enters., LLC, 601 B.R. 451 (Bankr. E.D. Mich. 2019). · cites it 2× “See Mich. Comp. Laws Ann. § 600.3201 , et seq.”
Bank of the Commonwealth v. Bevan, 13 B.R. 989 (E.D. Mich. 1981). “§ 600.3201 et seq. While the nature and extent of the debtor’s interest in real property is determined by application of state law, the Bankruptcy Code defines those interests in property which become *991 “property of the estate” and hence within the jurisdiction of the…”
Arnold v. DMR Fin. Servs., Inc., 532 N.W.2d 852 (Mich. 1995). · cites it 2× “Defendant proceeded to foreclose 1 by advertisement pursuant to MCL 600.3201 et seq.; MSA 27A.3201 et seq.”
Church & Church, Inc. v. A-1 Carpentry, 766 N.W.2d 30 (Mich. Ct. App. 2008). “Moreover, that is not an entirely correct statement regarding the purpose of the statute: The [precursor] statute [to MCL 600.”
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