While lenders and servicers with New York portfolios should long have been exceptionally familiar with the requirement, such presumed awareness nonetheless seems to little diminish the constant—often fatal losses suffered. And so it has been our wont to be appalled by constant lender defeats for all the years the mandatory 90-day notice prerequisite to declaring due the home loan mortgage balance has been in existence. Foreclosing mortgage holders lose on this point with unceasing regularity, confirmed by case law—yet again.