Ariz. Rev. Stat. » Title 33
Arizona Revised Statutes

Ariz. Rev. Stat. § 33-820 (2026)

Trustee's right to rely; attorney's right to act for trustee and beneficiary

✓ current as of May 2026
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A. In carrying out his duties under the provisions of this chapter or any deed of trust, a trustee, shall when acting in good faith, have the absolute right to rely upon any written direction or information furnished to him by the beneficiary.

B. An attorney for the beneficiary shall also be qualified to act as attorney for the trustee or to be the trustee.

Notes of Decisions
Cited in 6 cases (1 in the last 5 years), 1976–2021 · leading case: Cervantes v. Countrywide Home Loans, Inc., 656 F.3d 1034 (9th Cir. 2011).
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Cervantes v. Countrywide Home Loans, Inc., 656 F.3d 1034 (9th Cir. 2011). “” Ariz.Rev.Stat. § 33-820(A). Thus, Tiffany & Bosco did not have an obligation to consider whether its presumptively legal appointment as trustee, which was recorded in the county records, was invalid based on the original designation of MERS as a beneficiary.”
Kenly v. Miracle Props., 412 F. Supp. 1072 (D. Ariz. 1976). · cites it 2× “A.R.S. § 33-820. Trustee’s right to rely; attorney’s right to act for trustee and beneficiary.”
Schoonover v. Arizona Title Ins. & Trust Co., 616 P.2d 898 (Ariz. Ct. App. 1980). · cites it 2× “The question of any immunity from liability on the trustee’s part pursuant to A.R.S. § 33-820 has not been urged on this appeal.”
Amato v. Holladay Bank & Trust (D. Ariz. 2020). · cites it 5× “”13 4 As for A.R.S. § 33-820(A), that statute provides that “[i]n carrying out his duties 5 under the provisions of this chapter or any deed of trust, a trustee, shall when acting in 6 good faith, have the absolute right to rely upon any written direction or information 7…”
Marceaux v. Tiffany & Bosco (Ariz. Ct. App. 2020). · cites it 2× “” A.R.S. § 33-820(A). Marceaux defaulted on her loan.”
Brosnahan v. Caliber Home Loans Inc. (D. Ariz. 2021). · cites it 2× “16 2011) (citing A.R.S. § 33-820(A)). 17 The Court is not persuaded that the second element in the Puzz test is satisfied.”
— Ariz. Rev. Stat. § 33-820(A) — 4 cases
Cervantes v. Countrywide Home Loans, Inc., 656 F.3d 1034 (9th Cir. 2011). “” Ariz.Rev.Stat. § 33-820(A). Thus, Tiffany & Bosco did not have an obligation to consider whether its presumptively legal appointment as trustee, which was recorded in the county records, was invalid based on the original designation of MERS as a beneficiary.”
Amato v. Holladay Bank & Trust (D. Ariz. 2020). “”13 4 As for A.R.S. § 33-820(A), that statute provides that “[i]n carrying out his duties 5 under the provisions of this chapter or any deed of trust, a trustee, shall when acting in 6 good faith, have the absolute right to rely upon any written direction or information 7…”
Marceaux v. Tiffany & Bosco (Ariz. Ct. App. 2020). “” A.R.S. § 33-820(A). Marceaux defaulted on her loan.”
Brosnahan v. Caliber Home Loans Inc. (D. Ariz. 2021). “16 2011) (citing A.R.S. § 33-820(A)). 17 The Court is not persuaded that the second element in the Puzz test is satisfied.”
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