First Circuit: Harry, Jr. v. Countrywide Home Loans, Inc.

Fraud that voids a transaction ab initio does not toll or waive the relevant statute of limitations for actions to claiming fraud that voids a transaction ab initio.

Tolling a statute of limitations due to fraudulent concealment requires a threshold showing of due diligence by the movant, which can be disproved by delays in filing.

Acceleration of a mortgage note does not affect the time limits under state law on the right to foreclose.

Mortgagor does not have a private right of action against mortgagee under state mortgage licensing law.

http://media.ca1.uscourts.gov/pdf.opinions/16-2380P-01A.pdf