March 27, 2026
On March 27, 2026, Law360 published an “Expert Analysis” piece written by Schlam Stone & Dolan partner Joshua Wurtzel concerning a recent decision addressing the concept of a “qualified transferee” in U.C.C. foreclosures.
In the article, titled “When ‘Qualified Transferees’ Can Chill UCC Foreclosures,” Mr. Wurtzel describes a January 2026 decision by Justice Andrea Masley of the New York County Commercial Division in which the court, after initially granting a TRO enjoining a U.C.C. foreclosure, rejected the debtor’s challenge to the foreclosure and held that a requirement that prospective bidders be “qualified transferees,” as defined by the relevant intercreditor agreement, did not render the sale commercially unreasonable.
A copy of the article is attached, and can also be accessed here.