Equity of Redemption and Law of Mortgages

Mortgages provide for the repayment of the loanas foreclosure.
on a specified date. The effect of failure toForeclosure
redeem on the due date meant that the legalA foreclosure puts an end to the equitable right
right of the mortgagor to extinguish theto redeem and so destroys the equity of
mortgagee's rights had gone forever, and inredemption. It therefore follows that the right to
addition, the mortgagee could sue for repaymentforeclosure cannot arise until the legal date for
of the loan. This did not appeal to equity,redemption has passed; for only then does the
therefore the courts evolved a rule that theequitable right - which is the victim in a
mortgagor could redeem the mortgage by payingforeclosure action - arise. An action may
back the mortgage debt and all interest on it atapparently commence immediately the legal date
any time before the mortgagee sold orhas passed, but in practice however, an action for
foreclosed. This has had a major impact on newforeclosure is not usually begun except after such
home owners versus the frequency of Jamaicadefault as might justify a sale. While the matter
home rentals.of frequency is not a grave concern it does
This right of the mortgagor to redeem after theaffect Jamaica home rentals positively, so rent
due date is his equitable right to redeem. Butincome increases for some property investors.
from the start of the mortgage, the mortgagorThe effect of a foreclosure is that it vests in the
has been possessed of a species of equitablemortgagee the fee simple (or the whole of the
interest known as the equity of redemption.mortgagor's estate) and it also extinguishes the
This interest is a bundle of equitable rights,mortgagee's mortgage term and other
including the equitable right to redeem.subsequent mortgages. But prior mortgages are
Law of mortgagesnot affected by the foreclosure: they still subsist
A mortgage is a form of security for theand the result is that the foreclosing mortgagee
repayment of money lent. Mortgagor (Borrower)will have to redeem these prior mortgages if he
is the party who conveys the property by waywishes to be absolute master of the property.
of security. Mortgagee is the lender who obtainsFor example, suppose there are four mortgages
an interest in the property. The importance of theof the fee simple in the property which were
mortgage is that if the borrower fails to repaymade to A, B, C and D in that order.
the mortgage debt, the lender has the powersIf it forecloses, then the unencumbered fee
under the mortgage, of realizing the value of thesimple vests in him because all the subsequent
mortgaged property and repaying himself out ofmortgagees, that is, those of B, C and D are
the proceeds.extinguished. But if C forecloses, he only
Equity of Redemption - suppose a house worthextinguishes D's mortgage, those of A and B
$100,000 was mortgaged to secure a loan ofremain and he must redeem these mortgages by
25,000. Obviously, the mortgagor still has assetpaying off A and B if he wishes to have the
worth $75,000. This is an equitable estate - theproperty unencumbered. Of course, in any
equity of redemption. Without paying off theforeclosure action by a mortgagee, subsequent
mortgage, the borrower can sell, lease or devisemortgage must be made parties to the action
his interest. This is in fact transferring the equityand are also given the opportunity to redeem the
of redemption. He can also mortgage it, so thatmortgage of the foreclosing mortgagee. Thus, in
there may be a number of mortgages affectingour example, when A was foreclosing, B, C or D
the property.could pay off A and redeem A's mortgage, thus
The mortgagor has two rights to redeem hispreventing their own mortgage from becoming
property:extinguished.
1) The contractual right on the date specified inThis principle has given rise to the saying,
the deed, and,"redeem up, and foreclose down". Therefore, any
2) The equitable right to redeem, on payment ofmortgagee can foreclose in an action to recover
principal of the loan, the accrued interest alongland and action must be brought within twelve
with fees and loan costs, and establishing properyears from the date upon which the right of
notice to the mortgagee. This does not takerecovery accrues.
effect until and unless the contractual right (theJamaica real estate agents with house rentals
mortgagors prerogative) to redeem, on the datehave identified that in recent times they have
fixed in the mortgage has passed. This process ofseen a growing number of listings coming from
curtailing the equitable right to redeem and sofinancial institutions as they are unable to divest
leaving the mortgagee with a fee simple is knownforeclosed properties.