Washington Federal v. Gentry

¶1 The Deeds of Trust Act generally prohibits an action for a deficiency judgment against a guarantor of a loan following a trustee’s sale under a deed of trust *473securing that loan.1 But exceptions to this general rule apply to a guarantor of certain commercial loans.2

¶2 In this action, Washington Federal seeks a deficiency judgment against Kendall Gentry and Nancy Gentry. They executed guaranties of payment for commercial loans to three borrowers that they control. Based on its reading of RCW 61.24.100, the trial court granted the Gentrys’ motion for summary judgment of dismissal of this…