9th Circuit: PTFA Does Not Provide a Private Right of Action

Protecting Tenants at Foreclosure Act of 2009 (“PTFA”), Pub. L. No. 111-22, § 701–04, 123 Stat. 1632, 1660–62 (2009), requires purchasers of a foreclosed property to give tenants a minimum of 90 days notice before evicting them. The Ninth Circuit Court of Appeal held: PTFA does not, implicitly or explicitly, evince a congressional intent to create a private right of action.
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Robin Mashal
Los Angeles, California
Commercial Litigation
(310) 286-2000

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I am a litigation lawyer, licensed to practice law in the State of California. You can reach me by phone at (310) 286-2000.