BSP GIGI LLC v. Dixon

In this nonpayment proceeding, the tenant moved to dismiss for failure to state a cause of action, arguing the landlord's 14-day rent demand was defective. The court found that because the property's mortgage, originally private, was assigned to the Federal National Mortgage Association (Fannie Mae) in 2019, it became a "covered unit" under the CARES Act. Consequently, the landlord was required to serve a 30-day notice, not a 14-day notice. As the predicate notice was defective and cannot be amended, the tenant's motion was granted, and the proceeding was dismissed without prejudice.