Shore West Construction Co. v. Sroka

Upon review, we hold that a loan obtained for purposes of purchasing real estate may be a “consumer loan” under R.C. 2323.13(E)(1).

R.C. 2323.13(E) states in pertinent part:

“A warrant of attorney to confess judgment * * *, arising out of a consumer loan or consumer transaction, is invalid and the court shall have no jurisdiction to render a judgment based upon such a warrant. * * *

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“As used in this section:

“(1) ‘Consumer loan’ means a loan to a natural person and the debt incurred is primarily for a personal, family, educational, or household purpose. The term ‘consumer loan’ includes…