The Massachusetts Supreme Judicial Court affirmed a Land Court ruling invalidating foreclosure sales because the trustees of two securitized trusts could not show they were the mortgage holders at the time of sale. U.S. Bank, N.A. v. Ibanez, 458 Mass. 637 (2011). The court rejected post foreclosure assignments to the trusts, finding Massachusetts law requires the foreclosing entity to hold the mortgage at the time of notice and sale. The court found evidence of pre foreclosure assignment was not sufficient either. Although both trustees provided assignment agreements, those agreements did not include any listing indicating the loans in question were assigned or any evidence the assigning entity ever held the mortgage being assigned.