Approved Concepts from 7/28/08 meeting
Process Statute Problems/Requests Suggested Language
1 Commence Foreclosure 38-38-101 a Remove requirement for submitter to send a CN when not needed 38-38-101(1)(d) A combined notice pursuant to section 38-38-103;(I) THE COMBINED NOTICE MAY BE OMITTED WITH THE APPROVAL OF THE OFFICER;
      c Allow a Holder to file a foreclosure without an attorney.  Also we do not need to show ALL attorneys. 38-38-101(4)(j) The name, address, AND TELEPHONE NUMBER OF THE LAW FIRM, and THE bar registration number of the AN attorney for the holder of the evidence of debt, IF ANY, which may be indicated in the signature block of the notice of election and demand.                                                              
      d "Description of property" may not mean legal desc 38-38-101(4)(g) A LEGAL description of the property AS SET FORTH IN THE DEED OF TRUST;
      e Indorsement section is poorly worded. 38-38-101(6) Indorsement or assignment. PROPER INDORSEMENT OR ASSIGNMENT OF AN EVIDENCE OF DEBT SHALL INCLUDE THE ORIGINAL INDORSEMENT OR ASSIGNMENT, OR A CERTIFIED COPY OF AN INDORSEMENT OR ASSIGNMENT RECORDED IN THE COUNTY WHERE THE PROPERTY BEING FORECLOSED IS LOCATED. The original evidence of debt or a copy thereof without proper indorsement or assignment shall be deemed to be properly indorsed or assigned if a qualified holder presents the original evidence of debt or a copy thereof to the officer together with a statement in the certification of the qualified holder or in the statement of the attorney for the qualified holder pursuant to subparagraph (II) of paragraph (b) of subsection (1) of this section that the party on whose behalf the foreclosure was commenced is the holder of the evidence of debt.  Proper indorsement or assignment of an evidence of debt shall also include, in addition to the original indorsement or assignment, a certified copy of an indorsement or assignment recorded in the county where the property being foreclosed is located.
      f Deposit of $500.00 is insufficient 38-38-101(10) Deposit. The public trustee may require a deposit of up to five SIX hundred AND FIFTY dollars at the time the notice of election and demand is filed, to be applied against the fees and costs of the public trustee. 
2 Combined Notice 38-38-103 a Do not always need both an initial and a supplemental mailing list 38-38-103(1) (a) The public trustee shall mail a combined notice as described in subsection (4) of this section to the following persons as set forth in the initial mailing list as follows:
      c Omit mailing to PT  38-38-103(1)(a)(I)(B) Any person, EXCEPT THE PUBLIC TRUSTEE NAMED IN THE DEED OF TRUST, known or believed by the holder of the evidence of debt to be personally liable under the evidence of debt secured by the deed of trust or other lien being foreclosed at the last address, if any, shown in the records of the holder; and                        38-38-103(1)(a)(II)(C) Any person, EXCEPT THE PUBLIC TRUSTEE NAMED IN THE DEED OF TRUST, known or believed by the holder of the evidence of debt to be personally liable under the evidence of debt secured by the deed of trust or other lien being foreclosed, at the last address, if any, shown in the records of the holder;
      d The information required for CN refers to information required for NED and may be in conflict.   38-38-103(4)(a)(IV) The name, address, and telephone number of each attorney, if any, representing the holder of the evidence of debt;     (Telephone number will be added to the NED requirements)
      e If supplemental list is filed late or when an amended mailing list is submitted, the CN is not required to show the continued date 38-38-103(4)(a)(VIII) THE DATE TO WHICH THE SALE HAS BEEN CONTINUED PURSUANT TO SECTION 38-38-101(f) OR SECTION 38-38-103(2)(a).
      f Copies of Statutes do not include 302 for Redemptions 38-38-103(4)(b) A legible copy of this section and sections 38-37-108, 38-38-104, 38-38-301, 38-38-302, 38-38-304, 38-38-305, and 38-38-306 shall be sent with all notices pursuant to this section.
      g Alter CN for publication to be only a Notice of Sale 38-38-103(5) (a) No more than sixty calendar days nor less than forty-five calendar days prior to the first scheduled date of sale, unless a longer period of publication is specified in the deed of trust or other lien being foreclosed, a deed of trust or other lien being foreclosed shall be deemed to require the officer to publish the combined notice, omitting THE STATEMENTS UNDER SUBPARAGRAPHS (II),  (III), AND (VIII) OF PARAGRAPH (a) OF SUBSECTION (4) OF THIS SECTION, OMITTING the copies of the statutes under paragraph (b) of subsection (4) of this section, and adding the first and last publication dates if not already specified in the combined notice, for four weeks, which means publication once each week for five consecutive weeks.
      h Officer should not have to review ALL publications 38-38-103(5)(b) The officer shall review all such publications THE PUBLICATION of the combined notice for accuracy.
3 Cure of Default 38-38-104 b Add time frame for PT to supply cure figures to submitter  38-38-104(2) (a) Promptly upon receipt of a notice of intent to cure by the officer, but no less than twelve calendar days prior to the date of sale, the officer shall transmit by mail, facsimile, or electronic means to the person executing the notice of election and demand a request for a statement of all sums necessary to cure the default. The statement shall be filed with the officer by the attorney for the holder or, if none, by the holder of the evidence of debt and shall set forth the amounts necessary to cure as identified in paragraph (b) of this subsection (2), with the same detail as required for a bid pursuant to section 38-38-106.   UPON RECEIPT OF THE STATEMENT BY THE OFFICER OF THE AMOUNTS NEEDED TO CURE, THE OFFICER SHALL TRANSMIT THE STATEMENT IN WRITING TO THE PERSON FILING THE NOTICE OF INTENT TO CURE THE DEFAULT.
      c Clarify that the filer is the one who requests updated figures 38-38-104 (6) FOLLOWING EXPIRATION OF THE PERIOD FOR WHICH THE CURE STATEMENT IS EFFECTIVE, BUT NO LESS THAN FIFTEEN CALENDAR DAYS PRIOR TO THE DATE OF SALE, THE PERSON WHO ORIGINALLY SUBMITTED THE NOTICE OF INTENT TO CURE MAY MAKE WRITTEN REQUEST TO THE PUBLIC TRUSTEE FOR UPDATED CURE FIGURES.  UPON RECEIPT BY THE PUBLIC TRUSTEE OF THE WRITTEN REQUEST FOR UPDATED CURE FIGURES, THE PROVISIONS OF SUBSECTION (2) OF THIS SECTION SHALL APPLY.
4 Bid 38-38-106 a The PT doesn't always have the interest rate for redemption calculations 38-38-106(2) . . . RATE OF INTEREST AS OF THE DATE OF SALE
      b There can be some unfair bidding practices - may need to address min & max bids 38-38-106(7)(a)  THE OFFICER MAY ESTABLISH WRITTEN POLICIES RELATING TO ALL ASPECTS OF THE FORECLOSURE SALE.
5 Set Sale Date 38-38-108 a Ag Determination, have to wait 10 business days 38-38-108(2) (a) (I) If it is not evident from the legal description contained in the deed of trust or other lien being foreclosed whether the property described therein is agricultural property, the officer shall make that determination UPON PRESENTATION OF ACCEPTABLE EVIDENCE THAT THE PROPERTY IS NOT AGRICULTURAL PROPERTY OR no less than ten calendar days nor more than twenty calendar days after the recording of the notice of election and demand. and THE OFFICER shall accept the following as evidence that the property is not agricultural property:
6 Continuance 38-38-109 b With later publications, a bankruptcy can be filed and cleared in time to maintain the original publication scheduled 38-38-109(2)(b) (I) If all THE publications of the combined notice prescribed by section 38-38-103 (5) or 13-56-201 (1), C.R.S., HAVE NOT BEEN STARTED OR IF ALL THE PUBLICATIONS have not been completed before a bankruptcy petition has been filed that automatically stays the officer from conducting the sale, the officer shall immediately cancel any remaining publications of the combined notice and, on the date set for the sale, announce, post, or provide a notice that the sale has been enjoined or has been stayed by the automatic stay provisions of the federal bankruptcy code of 1978, title 11 of the United States Code, as amended. The sale shall not be continued under paragraph (a) of subsection (1) of this section.
      c Court injunctions should be treated like bankruptcies 38-38-109(2)(d) If a sale is enjoined by court order, the same procedures as set forth in paragraphs (a), and (b), AND (c) of this subsection (2) shall apply unless the court order specifies otherwise.
7 Excess Proceeds 38-38-111 a Prior practice was to lower the deficiency by the amount of the overbid - now it is paid after the end of all redemption periods 38-38-111 (1) If, at a sale, the property is sold for an amount in excess of the sum of the fees and costs pursuant to section 38-37-104, the fees and costs of sale, and moneys due the holder of the evidence of debt secured by the deed of trust or other lien being foreclosed, such excess proceeds shall be FIRST APPLIED TO ANY DEFICIENCY AS INDICATED IN THE HOLDER'S BID, AND THEN paid to the officer to be held in escrow until the end of all redemption periods as provided in section 38-38-302.
8 Recission of Sale 38-38-113 a Refers to submission of the original COP 38-38-113(1) . . .Upon receipt of the notice of rescission of sale, the original certificate of purchase, any assignment of the certificate of purchase, the public trustee's fee for the rescission specified in section 38-37-104, and the costs of recording the notice of rescission of the sale, the public trustee shall record the notice of rescission of sale in the county records.
10 Release with Production of EOD form 38-39-107 a Contains references to Owner of Indebtedness rather than Holder of the Evidence of Debt Various places
11 Release without Production of EOD form 38-39-108 a Contains references to Owner of Indebtedness rather than Holder of the Evidence of Debt Various places
      b Language for Title Company Releases is not right 38-39-108 c. [ ] A title insurance company licensed and qualified in Colorado, as specified in § 38-39-102 (3) (c), Colorado Revised Statutes, that agrees that it is obligated to indemnify the Public Trustee for any and all damages, costs, liabilities, and reasonable attorney fees incurred PURSUANT TO STATUTE as a result of the action of the Public Trustee taken in accordance with this Request for Release.       
12 Other Items   b Waiver of cure rights should not affect future defaults 38-38-703.  A waiver of or agreement to shorten the time period to exercise the right to cure a default granted by the provisions of this article that is made before the date of THE default AS TO WHICH THE WAIVER IS GRANTED under a deed of trust, mortgage, or other instrument evidencing a lien or an evidence of debt secured thereby shall be void as against public policy.
      c Some references to Public Trustee's Deed still exist 38-37-112.  The public trustee of each county is declared to be the proper public trustee to issue public trustee's CONFIRMATION deeds, certificates of purchase, certificates of redemption, releases of deeds of trust, and all other documents required of a public trustee for all property located in that public trustee's county at the time of execution of such documents by the public trustee or at the time the deed of trust was recorded in that county.