Michigan Compiled Laws
Mich. Comp. Laws § 600.3205a (2026)
Repealed. 2012, Act 521, Eff. June 30, 2013.
✓ current as of July 2026
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REVISED JUDICATURE ACT OF 1961
Act 236 of 1961
600.3205a Repealed. 2012, Act 521, Eff. June 30, 2013.
Repealed. 2012, Act 521, Eff. June 30, 2013.
Compiler's Notes:
The repealed sections pertained to requirements for notice of foreclosure, loan modification program and process, and development of housing counselor list.
Notes of Decisions
Cited in 28
cases, 2011–2019 · leading case: Talton v. BAC Home Loans Servicing LP, 839 F. Supp. 2d 896 (E.D. Mich. 2012).
Talton v. BAC Home Loans Servicing LP, 839 F. Supp. 2d 896 (E.D. Mich. 2012). “The notice states: This notice is being sent to the borrowers and/or mortgagors pursuant to MCL 600.3205a(l) pertaining to the mortgage for property located at 28885 Ranch-wood Dr Unit 7, Southfield, MI 48076-2465.”
Lopez v. Bank of Am., N.A., 920 F. Supp. 2d 798 (W.D. Mich. 2013). “The Court does note that some district courts have concluded that the language of § 600.3205a precludes relief after a foreclosure sale is completed.”
Kloss v. RBS Citizens, N.A., 996 F. Supp. 2d 574 (E.D. Mich. 2014). “In particular, section 600.3205a(e) of the Michigan Compiled Laws requires a lender to wait *586 90 days before commencing foreclosure proceedings against a borrower who has requested a meeting with the lender, which Defendant appears to have complied with.”
Viola Chambers v. HSBC Bank USA, N.A., 796 F.3d 560 (6th Cir. 2015). “42-43 (citing MCL § 600.3205a(l)).) Chambers was prejudiced, she claims, because the defendants’ failure to provide full notice deprived her of the chance to seek a loan modification.”
Banacki v. OneWest Bank, FSB, 276 F.R.D. 567 (E.D. Mich. 2011). “§ 600.3205a. On September 28, 2009, MERS assigned Banaeki’s mortgage to OneWest.”
Collins v. Wickersham, 862 F. Supp. 2d 649 (E.D. Mich. 2012). “Plaintiffs allege violations of Michigan’s loan modification statute, Michigan Compiled Laws § 600.3205a et seq., but courts in the Eastern District of Michigan have uniformly held that such violations are insufficient to justify setting aside a completed foreclosure sale.”
Dingman v. OneWest Bank, FSB, 859 F. Supp. 2d 912 (E.D. Mich. 2012). “The complaint alleges eight counts, phrased by the plaintiffs as follows: Count I — Violation of MCL § 600.3205a Count II — Misrepresentation and/or Fraud Count III — Deceptive Act and/or Unfair Practice Count IV — Quiet Title Count V — Unjust Enrichment Count VI —…”
Faouaz Mourad v. Homeward Residential, Inc., 517 F. App'x 360 (6th Cir. 2013). “In any event, AHMSI presented unre-futed evidence that Mourad was mailed a notice of foreclosure that stated: Pursuant to MCL 600.3205a(l): Within 14 days after this notice is sent, you may request a meeting with [AHMSI’s law firm] to attempt to work out a modification of the…”
Frost v. Wells Fargo Bank, N.A., 901 F. Supp. 2d 999 (W.D. Mich. 2012). “comp, laws § 600.3205a (id.). Additionally, Plaintiffs argue that they requested a loan modification prior to the notice of sheriffs sale and that Orlans initiated the foreclosure in violation of Mich.”
Henson v. Bank of Am., N.A., 979 F. Supp. 2d 763 (E.D. Mich. 2013). “3205(l)(g),” the Court will presume that the plaintiffs miscitation is intended to refer to Michigan Compiled Laws § 600.3205a(l)(g), the language of which is quoted in the complaint.”
Bank of New York Mellon v. Robert L Carmack (Mich. Ct. App. 2015). “Defendant argued that plaintiff was not the foreclosing entity; rather, Bank of America was the foreclosing entity, but it was never assigned the mortgage as required under MCL 600.”
Constantine Nitsos v. Fifth Third Bank (Mich. Ct. App. 2015). “Finally, Nitsos alleged that he was entitled to declaratory relief on several outstanding issues, including whether the 1 The Legislature repealed MCL 600.3205a to MCL 600.3205d, effective June 2013.”
— Mich. Comp. Laws § 600.3205a(1) — 4 cases
Constantine Nitsos v. Fifth Third Bank (Mich. Ct. App. 2015). “Finally, Nitsos alleged that he was entitled to declaratory relief on several outstanding issues, including whether the 1 The Legislature repealed MCL 600.3205a to MCL 600.3205d, effective June 2013.”
Francis Katulski v. Cpca Trust I (Mich. Ct. App. 2015).
Samuel L Hill Jr v. US Bank Na (Mich. Ct. App. 2015).
Samuel L Hill Jr v. US Bank Na (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 600.3205a(1)(c) — 1 case
Frederick Franzel Jr v. Nationstar Mortg. LLC (Mich. Ct. App. 2014).
— Mich. Comp. Laws § 600.3205a(3) — 3 cases
James H Diluigi v. Rbs Citizens Na (Mich. 2015).
James H Diluigi v. Rbs Citizens Na (Mich. 2015).
Terees Williams v. Fannie Mae (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 600.3205a(4) — 1 case
Lopez v. Bank of Am., N.A., 920 F. Supp. 2d 798 (W.D. Mich. 2013). “The Court does note that some district courts have concluded that the language of § 600.3205a precludes relief after a foreclosure sale is completed.”
— Mich. Comp. Laws § 600.3205a(5) — 3 cases
Collins v. Wickersham, 862 F. Supp. 2d 649 (E.D. Mich. 2012). “Plaintiffs allege violations of Michigan’s loan modification statute, Michigan Compiled Laws § 600.3205a et seq., but courts in the Eastern District of Michigan have uniformly held that such violations are insufficient to justify setting aside a completed foreclosure sale.”
Bank of New York Mellon v. Robert L Carmack (Mich. Ct. App. 2015). “Defendant argued that plaintiff was not the foreclosing entity; rather, Bank of America was the foreclosing entity, but it was never assigned the mortgage as required under MCL 600.”
Terees Williams v. Fannie Mae (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 600.3205a(d) — 1 case
Chinita Terry v. Fed. Nat'l Mortg. Ass'n (Mich. Ct. App. 2015).
— Mich. Comp. Laws § 600.3205a(e) — 1 case
Kloss v. RBS Citizens, N.A., 996 F. Supp. 2d 574 (E.D. Mich. 2014). “In particular, section 600.3205a(e) of the Michigan Compiled Laws requires a lender to wait *586 90 days before commencing foreclosure proceedings against a borrower who has requested a meeting with the lender, which Defendant appears to have complied with.”
— Mich. Comp. Laws § 600.3205a(l) — 3 cases
Viola Chambers v. HSBC Bank USA, N.A., 796 F.3d 560 (6th Cir. 2015). “42-43 (citing MCL § 600.3205a(l)).) Chambers was prejudiced, she claims, because the defendants’ failure to provide full notice deprived her of the chance to seek a loan modification.”
Talton v. BAC Home Loans Servicing LP, 839 F. Supp. 2d 896 (E.D. Mich. 2012). “The notice states: This notice is being sent to the borrowers and/or mortgagors pursuant to MCL 600.3205a(l) pertaining to the mortgage for property located at 28885 Ranch-wood Dr Unit 7, Southfield, MI 48076-2465.”
Faouaz Mourad v. Homeward Residential, Inc., 517 F. App'x 360 (6th Cir. 2013). “In any event, AHMSI presented unre-futed evidence that Mourad was mailed a notice of foreclosure that stated: Pursuant to MCL 600.3205a(l): Within 14 days after this notice is sent, you may request a meeting with [AHMSI’s law firm] to attempt to work out a modification of the…”
— Mich. Comp. Laws § 600.3205a(l)(b) — 1 case
Jackson v. Bank of Am., N.A., 67 F. Supp. 3d 828 (E.D. Mich. 2014).
— Mich. Comp. Laws § 600.3205a(l)(c) — 1 case
Talton v. BAC Home Loans Servicing LP, 839 F. Supp. 2d 896 (E.D. Mich. 2012). “The notice states: This notice is being sent to the borrowers and/or mortgagors pursuant to MCL 600.3205a(l) pertaining to the mortgage for property located at 28885 Ranch-wood Dr Unit 7, Southfield, MI 48076-2465.”
— Mich. Comp. Laws § 600.3205a(l)(g) — 1 case
Henson v. Bank of Am., N.A., 979 F. Supp. 2d 763 (E.D. Mich. 2013). “3205(l)(g),” the Court will presume that the plaintiffs miscitation is intended to refer to Michigan Compiled Laws § 600.3205a(l)(g), the language of which is quoted in the complaint.”
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