Mealey's (March 14, 2022, 9:11 AM EDT) -- RICHMOND, Va. — A federal district court did not err in ruling that a substitute trustee in a foreclosure dispute was fraudulently joined in the litigation because a borrower has failed to provide any controlling precedent to support his construction of the trustee’s implied fiduciary obligations in the underlying foreclosure proceedings after the execution of a loan modification agreement (LMA), a Fourth Circuit U.S. Court of Appeals panel ruled Feb. 24 in affirming in an unpublished per curiam summary order....