In the case of 1842752 Ontario Inc. v. Fortress Wismer 3-2011 Ltd.[1](the "Fortress Case"), the Ontario Court of Appeal held that a judgment creditor is not entitled to enforce a writ of seizure and sale against a registered owner that beneficially holds land in trust for a judgment debtor, nor to priority over arm's length construction financing.

In an apparent case of first impression in Massachusetts, the US Bankruptcy Court for the District of Massachusetts recently held that an allonge must be physically affixed to the original promissory note to be effective.