Nev. Rev. Stat. » NRS: CHAPTER 106 - REAL MORTGAGES
Nevada Revised Statutes

Nev. Rev. Stat. § 106.210 (2026)

Recording of assignments of mortgages or beneficial interests in deeds of trust; constructive notice; effect of unrecorded assignments

✓ current as of July 2026
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NRS 106.210  Recording of assignments of mortgages or beneficial interests in deeds of trust; constructive notice; effect of unrecorded assignments.

      1.  Any assignment of a mortgage of real property and any assignment of the beneficial interest under a deed of trust must be recorded in the office of the recorder of the county in which the property is located, and from the time any of the same are so filed for record shall operate as constructive notice of the contents thereof to all persons. A mortgage of real property which has been assigned may not be enforced unless and until the assignment is recorded pursuant to this subsection. If the beneficial interest under a deed of trust has been assigned, the trustee under the deed of trust may not exercise the power of sale pursuant to NRS 107.080 unless and until the assignment is recorded pursuant to this subsection.

      2.  Each such filing or recording must be properly indexed by the recorder.

      [Part 1:120:1935; 1931 NCL § 2122.31]—(NRS A 1965, 924; 2011, 327, 1748; 2021, 1415)

     

Notes of Decisions
Cited in 42 cases (4 in the last 5 years), 1969–2025 · leading case: Daisy Trust v. Wells Fargo Bank, N.A., 445 P.3d 846 (Nev. 2019).
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Daisy Trust v. Wells Fargo Bank, N.A., 445 P.3d 846 (Nev. 2019). · cites it 7× “Daisy Trust points to NRS 106.210 and NRS 111.325 as the relevant statutes.”
Edelstein v. Bank of New York Mellon, 286 P.3d 249 (Nev. 2012). · cites it 4× “Thus, the borrower, or grantor, executes both the note and the deed of trust in favor of the lender, who was historically the beneficiary under both, and who names a trustee on the deed of trust “to assure the payment of the debt secured by the trust deed.”
Alex Berezovsky v. Bank of Am., 869 F.3d 923 (9th Cir. 2017). · cites it 2× “See Nev. Rev. Stat. § 106.210 . 7 If the named beneficiary under the recorded deed of trust is someone other than the note owner, the recordation separates “the note and the security deed [and] creates a question of what entity would have authority to foreclose, but does not…”
Rh Kids, LLC v. Mtc Fin., 367 F. Supp. 3d 1179 (D. Nev. 2019). · cites it 2× “3d at 932 (citing NRS § 106.210 ). However, the recorded instrument need not list the note owner by name.”
Dixon v. Thatcher, 742 P.2d 1029 (Nev. 1987). “NRS 106.210 provides as relevant: “[A]ny assignment of the beneficial interest under a deed of trust may be recorded, and from the time any of the same are so filed for record shall operate as constructive notice of the contents thereof to all persons.”
In re Danastorg, 499 B.R. 8 (Bankr. D. Mass. 2013). “” NRS 106.210. To permit an entity that is not really the beneficiary to record itself as the beneficiary would defeat the purpose of the recording statute and encourage a lack of transparency.”
Lakes v. U.S. Bank Tr., 2021 NV 85 (Nev. 2021). · cites it 12× “Bank Trust's deed-of-trust lien is enforceable under NRS 106.210, which governs recording requirements for deed-of-trust assignments.”
Daisy Tr. Vs. Wells Fargo Bank, N.A., 2019 NV 30 (Nev. 2019). · cites it 10× “" However, when Freddie Mac acquired the loan in 2007, NRS 106.210 provided that "any assignment of the beneficial interest under a deed of trust may be recorded.”
Dang v. Loancare, LLC (D. Nev. 2025). · cites it 10× “) 6 According to Dang, there are accordingly three ‘procedural defects’ in the 7 transferring of the servicing of his loan; (1) the promissory note was severed from the 8 deed of trust since it was never recorded in violation of NRS § 106.210; (2) the promissory 9 note and deed…”
Sfr Inv.'s Pool 1, LLC v. Green Tree Serv., LLC (Nev. 2018). · cites it 7× “135, Nevada's business-records exception to the rule excluding hearsay evidence) Much of SFR's remaining argument is premised upon its allegation that Fannie Mae had to record the assignment of the loan when it purchased it in 2007, citing NRS 106.210. Specifically, SFR asserts…”
Onewest Bank Fsb v. Holm Int'l Prop.'s, LLC (Nev. 2018). · cites it 6× “Much of Holm's argument is premised upon its allegation that Fannie Mae had to record its interest in the property when it purchased it in 2007, citing NRS 106.210. Specifically, Holm asserts that even if the Federal Foreclosure Bar preempts Nevada's super-priority lien law…”
M&T Bank v. Wild Calla St. Tr. (Nev. 2019). · cites it 5× “Both the district court and Wild Calla mistakenly relied on the 2011 version of NRS 106.210, the relevant 2 We recognize that the district court did not have the benefit of our opinion in Saticoy Bay LLC Series 9641 Christine View v.”
Show all 42 citing cases →
— Nev. Rev. Stat. § 106.210(1) — 7 cases
Daisy Trust v. Wells Fargo Bank, N.A., 445 P.3d 846 (Nev. 2019). “Daisy Trust points to NRS 106.210 and NRS 111.325 as the relevant statutes.”
Daisy Tr. Vs. Wells Fargo Bank, N.A., 2019 NV 30 (Nev. 2019). “" However, when Freddie Mac acquired the loan in 2007, NRS 106.210 provided that "any assignment of the beneficial interest under a deed of trust may be recorded.”
Nationstar Mortg. LLC v. Inverest LLC (D. Nev. 2020).
White v. 5 Arch Income Fund 2, LLC (D. Nev. 2023).
Sfr Inv.'s Pool 1, LLC v. Green Tree Serv., LLC (Nev. 2018). “135, Nevada's business-records exception to the rule excluding hearsay evidence) Much of SFR's remaining argument is premised upon its allegation that Fannie Mae had to record the assignment of the loan when it purchased it in 2007, citing NRS 106.210. Specifically, SFR asserts…”
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