In Federal National Mortgage Association v Villa Del Lago Condo. Assn, an unpublished Michigan Court of Appeals opinion, the court of appeals held that a condominium association was only able to collect from FNMA assessments which accrued subsequent to a foreclosure sale, in line with the decisions rendered previously and discussed here and here. The court also held that FNMA’s slander of title claim was properly dismissed, because there was no bad faith in the recording of the association lien.
The law now seems fairly settled in Michigan that a foreclosing first mortgage lender, or its assigns and grantees, are liable for assessments only from the date of the mortgage foreclosure sale forward.