Pnc Bank, National Association v. Smith

In the Supreme Court of Georgia Decided: February 22, 2016 S15Q1445. PNC BANK, NATIONAL ASSOCIATION v. SMITH et al. MELTON, Justice. In this case regarding the requirements of Georgia’s foreclosure confirmation statute, OCGA § 44-14-161,1 the United States District Court for the Northern District of Georgia has certified two questions: (1) Is a lender’s compliance with the requirements contained in OCGA § 44-14-161 a condition precedent to the lender’s ability to pursue a borrower and/or guarantor for a deficiency after a foreclosure has been conducted? (2) If so, can borrowers or This…