also Michael Powell & Gretchen Morgenson, MERS? It May Have Swallowed Your Loan, N.Y. Times, March 6, 2011, http://www.nytimes.com/ 201 l/03/06/business/06mers.html (describing the “mounting” legal challenges facing MERS). The obvious advantage of the MERS System is that it allows residential lenders to avoid the bother and expense of recording every change of ownership of promissory notes. See, e.g., Phyllis K. Slesinger & Daniel McLaughlin, Mortgage Electronic Registration System, 31 Idaho L.Rev. 805, 808 (1995); About Us, MERS, http:// www.mersinc.org/about-us/about-us (last visited May 5, 2014) (stating that MERS was “created by the mortgage banking industry to streamline the mortgage process”). Critics have pointed out, however, that v. Cin Kham, 278 P.3d 586, 592-93 (Okla.2012) (<HOLDING>); Brandrup v. ReconTrust Co., N.A., 353 Or.
holding that mers lacked standing to foreclose as the lenders nominee holding that the putative noteholder lacked standing to foreclose because mers lacked authority to assign the note though it arguably had authority to assign the mortgage holding that because plaintiff failed to assign error to the dismissal of one its claims that issue was not properly before this court holding that even if the individual who signed the mortgage assignment lacked the authority to do so the assignment would still be binding on mers because he purported to be authorized holding that because a mortgage provides the security for the repayment of the note the person having standing to foreclose a note secured by a mortgage may be either the holder of the note or a nonholder in possession of the note who has the rights of a holder