HSBC Bank USA, N.A. v Roumiantseva | NY App. Div. 2nd Dept. - MERS was never the holder of the note and, therefore, was without authority to assign the note...purported endorsement, attached by a paperclip, was not so firmly affixed to the note did not constitute a valid transfer of the underlying note
Decided on July 29, 2015 SUPREME COURT OF THE STATE OF NEW YORK Appellate Division, Second Judicial Department PETER B. SKELOS, J.P. L. PRISCILLA HALL

