The Tennessee Supreme Court held that commencement of a foreclosure proceeding does not constitute an "increase in hazard" under the terms of an insurance policy or statutory provisions, and thus the lender was not required to give the insurance company notice regarding the foreclosure proceedings. The court reversed the judgment of the lower court which precluded the lender from receiving insurance proceeds when the building was destroyed after foreclosure proceeds had been commenced and the lender had failed to notify the insurer. U.S. Bank, N.A. as servicer for the Tennessee Housing Development Agency v. Tennessee Farmers Mutual Insurance Company, Case No. W2006-02536-SC-R11-CV (Tenn. 2008).