Glaski v. Bank of America, N.A., 218 Cal. App. 4th 1079 (July 31, 2013) -  “a borrower may challenge [a] securitized trust’s chain of ownership by alleging the attempts to transfer the deed of trust to the securitized trust (which was formed under New York law) occurred after the trust’s closing date.”
Diunugala is the first case coming out of a California court to expressly reject the California Court of Appeal’s reasoning inGlaski and deem Glaski unpersuasive. While not binding authority, other State and Federal Courts in California may followDiunugala as persuasive authority and similarly follow well-established case law holding that a borrower lacks standing to challenge an allegedly invalid assignment of a deed trust.