Mortgage Purchase & Sales Co. v. Williamson

“An agreement by a creditor to receive less than the amount of his debt can not be pleaded as an accord and satisfaction, unless it be actually executed by the payment of the money, or the giving of additional security, or the substitution of another debtor, or some other new consideration.” Code, § 20-1204. “The accord and satisfaction must be of some advantage, legal or equitable to the creditor.” § 20-1203. In the absence of a bona fide dispute, mere surrender by the debtor of money already paid or property already admittedly belonging to the creditor, where no advantage or benefit accrues…