Hew Federal Credit Union v. Battle

FARRELL, Associate Judge:

The issue before us, one of first impression in the District of Columbia but by no means a stranger to other courts, is whether a guarantor of a secured loan who does not own the collateral is nevertheless a “debtor” within the meaning of Title 9 of the Uniform Commercial Code (“UCC”), D.C.Code § 28:9-101 et seq. (1996), so as to require the creditor to give the guarantor notice of a foreclosure sale in accor*253dance with the UCC. In line with the vast majority of courts deciding the issue, we answer “yes.” Since notice was not given to the guarantor Battle, the trial…