On March 7, the California Supreme Court, in Sheen v. Wells Fargo Bank, limited the tort liability of lenders and servicers. The court held that lenders and servicers do not owe borrowers a duty of care to "process, review and respond carefully and completely to" a borrower's loan modification application so as to avoid causing borrowers pure monetary loss through a lack of care in handling the application. This opinion provides a collective sigh of relief to those in the corner of lenders and servicers, but they should continue to tread lightly in the loss mitigation process because it is unlikely that this case will mark the end of similar, but more artfully crafted, complaints if certain additional facts are present.