[Note 1] Green Tree Servicing, LLC. [Note 2] The term mortgage note is used in this opinion to refer to the promissory note or other form of debt or obligation for which the mortgage provides security; and the term note holder is used to refer to a person or entity owning the mortgage note. [Note 3] We acknowledge the amicus briefs filed by Adam J. Levitin, pro se; WilmerHale Legal Services