A. The fact that a greater amount could have been obtained by a collection, enforcement, disposition or acceptance at a different time or in a different method from that selected by the secured party is not of itself sufficient to preclude the secured party from establishing that the collection, enforcement, disposition or acceptance was made in a commercially reasonable manner.
B. A disposition of collateral is made in a commercially reasonable manner if the disposition is made:
1. In the usual manner on any recognized market;
2. At the price current in any recognized market at the time of the disposition; or
3. Otherwise in conformity with reasonable commercial practices among dealers in the type of property that was the subject of the disposition.
C. A collection, enforcement, disposition or acceptance is commercially reasonable if it has been approved:
1. In a judicial proceeding;
2. By a bona fide creditors' committee;
3. By a representative of creditors; or
4. By an assignee for the benefit of creditors.
D. Approval under subsection C need not be obtained, and lack of approval does not mean that the collection, enforcement, disposition or acceptance is not commercially reasonable.
Notes of Decisions
FL Receivables Trust 2002-A v. Arizona Mills, L.L.C., 281 P.3d 1028 (Ariz. Ct. App. 2012).
· cites it 6× “First, we note that A.R.S. § 47-9627(A) and (B) suggest that disposition of property can be commercially reasonable in any market, even if a greater amount could be secured by waiting for a change in the market.”
Peters (D. Ariz. 2025).
· cites it 2× “17 See A.R.S. § 47-9627(A) (“The fact that a greater amount could have been obtained by a 18 collection, enforcement, disposition or acceptance at a different time or in a different 19 method from that selected by the secured party is not of itself sufficient to preclude the 20…”
Shapiro (D. Ariz. 2026).
· cites it 2× “§ 47-9627(A). 9 Second, a disposition will be considered commercially reasonable if “made: (1) [i]n the 10 usual manner on any recognized market; (2) [a]t the price current in any recognized market 11 at the time of the disposition; or (3) [o]therwise in conformity with…”
Citicapital Tech. Fin., Inc. v. Goodman, 280 F. App'x 601 (9th Cir. 2008).
“Contrary to the Goodmans’ assertion, there is ample evidence in the record demonstrating that the sale was done in a commercially reasonable manner as it was conducted in the usual manner in the recognized market of Ontario, California through public auctions and private sales…”
— Ariz. Rev. Stat. § 47-9627(A) — 3 cases
FL Receivables Trust 2002-A v. Arizona Mills, L.L.C., 281 P.3d 1028 (Ariz. Ct. App. 2012).
“First, we note that A.R.S. § 47-9627(A) and (B) suggest that disposition of property can be commercially reasonable in any market, even if a greater amount could be secured by waiting for a change in the market.”
Peters (D. Ariz. 2025).
“17 See A.R.S. § 47-9627(A) (“The fact that a greater amount could have been obtained by a 18 collection, enforcement, disposition or acceptance at a different time or in a different 19 method from that selected by the secured party is not of itself sufficient to preclude the 20…”
Shapiro (D. Ariz. 2026).
“§ 47-9627(A). 9 Second, a disposition will be considered commercially reasonable if “made: (1) [i]n the 10 usual manner on any recognized market; (2) [a]t the price current in any recognized market 11 at the time of the disposition; or (3) [o]therwise in conformity with…”
— Ariz. Rev. Stat. § 47-9627(B) — 2 cases
FL Receivables Trust 2002-A v. Arizona Mills, L.L.C., 281 P.3d 1028 (Ariz. Ct. App. 2012).
“First, we note that A.R.S. § 47-9627(A) and (B) suggest that disposition of property can be commercially reasonable in any market, even if a greater amount could be secured by waiting for a change in the market.”
Citicapital Tech. Fin., Inc. v. Goodman, 280 F. App'x 601 (9th Cir. 2008).
“Contrary to the Goodmans’ assertion, there is ample evidence in the record demonstrating that the sale was done in a commercially reasonable manner as it was conducted in the usual manner in the recognized market of Ontario, California through public auctions and private sales…”
— Ariz. Rev. Stat. § 47-9627(B)(1) — 1 case
Shapiro (D. Ariz. 2026).
“§ 47-9627(A). 9 Second, a disposition will be considered commercially reasonable if “made: (1) [i]n the 10 usual manner on any recognized market; (2) [a]t the price current in any recognized market 11 at the time of the disposition; or (3) [o]therwise in conformity with…”
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treatment. Dots show Syfertize treatment of the citing case itself.