The U.S. Court of Appeals for the Ninth Circuit recently held that a conditional offer from a lender was not a valid tender to satisfy the superpriority portion of an HOA lien……A condominium owner fell behind on the assessments she owed her homeowners association (“HOA”) and filed a Chapter 7 bankruptcy on Feb. 29, 2012. On July 2, 2013, the HOA’s collection agency recorded a notice of delinquent assessment lien on behalf of the HOA.    A copy of the opinion in Citimortgage, Inc. v. Corte Madera Homeowners Ass’n is available at: Link to Opinion.    Read the article…………………………