To embed, copy and paste the code into your website or blog: On February 18, 2021, the New York Court of Appeals’ consolidated resolution of four cases that answered two critical questions concerning the application of the statute of limitations in New York mortgage foreclosure actions: What constitutes a valid acceleration such that the six-year “clock” is started and what actions constitute a valid “de-acceleration” of a loan? Question 1: What starts the clock? The opinion discussed two cases, Wells Fargo Bank, N.V. v. Ferrato and Vargas v. Deutsche Bank National Trust, addressing acts that do — or do not — constitute valid acceleration. Like a majority of states, New York requires lenders to accelerate loans via an “unequivocal overt act.” In