Attorney fees are recoverable under sections 9 and 14 of the standard Fannie/Freddie deed of trust, but not as a separate fee award that may be enforced against the borrower’s other assets. Instead, those sections only permit the fees to be added to the loan principal secured by the deed of trust—and that is true even when the party recovering the fees does not own the loan (but is, for example, the loan servicer or a prior loan servicer sued on the deed of trust).
California Court of Appeal, Second District, Division 5 (Baker, Acting P.J.); September 19, 2018 (partial publication); 27 Cal. App. 5th 351