NEW ORLEANS - A Fifth Circuit U.S. Court of Appeals panel on Sept. 19 affirmed the dismissal of a man's wrongful foreclosure action for failure to state a claim after finding that Bank of America N.A. did not need to possess the underlying promissory note to foreclose on his property after he defaulted on his mortgage loan (Allan Kramer v. Federal National Mortgage Association, No. 12-51171, 5th Cir.; 2013 U.S. App. LEXIS 19324).