As of Feb. 14, 2023 the so called, and for lenders, infamous, "Kessler Doctrine" is gone—per a very well reasoned ruling of the Court of Appeals [Bank of America, N.A. v. Kessler, ___N.Y.3d___, ___N.E.3d___, ___N.Y.S.3d___ (Ct. of Appeals 2023)].