Bank of Am. v. Carlson

*506In U.S. Bank National Assn. v. McCoy , 290 Or. App. 525, 527, 415 P.3d 1116 (2018), a judicial foreclosure action like this one, we held that a statement in a bank employee's declaration, attesting that the bank's business records showed that the defendant's promissory note had been in the plaintiff's possession at the time it commenced foreclosure proceedings, was inadmissible to establish the plaintiff's standing to enforce the note. We concluded that, even though the bank records themselves were admissible under the hearsay exception for business records, the statement as to what those…