Over the past year, when the pandemic has caused a period of turmoil in the commercial real estate market, mortgage lenders have found it necessary to enter into amendments with many of their borrowers in order to avert defaults of their mortgage loans. Lenders, however, need to exercise special care that they do not risk losing lien priority when modifying their loan documents if the property is subject to a subordinate lien at the time of the closing of the amendment. One recent decision issued by New York's Appellate Division, Second Department, though favorable to the senior mortgage lender, highlights the consequences that may result should a lender fail to exercise caution when modifying their mortgage loans.