Iowa Code § 570A.4

Perfecting the lien — filing requirements

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Except as provided in this section, a financing statement filed to perfect an agricultural supply dealer lien shall be governed by chapter 554, article 9, part 5, in the same manner as any other financing statement. 1. The lien becomes effective at the time that the farmer purchases the agricultural supply. 2. In order to perfect the lien, the agricultural supply dealer must file a financing statement in the office of the secretary of state as provided in section 554.9308 within thirty-one days after the date that the farmer purchases the agricultural supply. The financing statement shall meet the requirements of section 554.9502, subsection 1, and include all applicable information described in section 554.9516. Filing a financing statement as provided in this subsection satisfies all requirements for perfection of an agricultural lien as provided in chapter 554, article 9. 84 Acts, ch 1072, §4; 85 Acts, ch 204, §4; 88 Acts, ch 1275, §40; 91 Acts, ch 267, §630; 2000 Acts, ch 1149, §177, 187; 2003 Acts, ch 82, §5 Referred to in §570A.5

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Notes of Decisions
Cited in 15 cases (2 in the last 5 years), 1990–2023 · leading case: Oyens Feed & Supply, Inc. v. Primebank
Oyens Feed & Supply, Inc. v. Primebank (2016) iowa · cites it 58× “In order to perfect the" lien, the agricultural supply dealer must file a financing statement in the office of the secretary of state as provided in section 554.9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
Wells Fargo Bank, N.A. v. Tama Benton Cooperative (In Re Shulista) (2011) ianb · cites it 58× “In Cross Motions for Summary Judgment, the parties seek an interpretation of Iowa Code § 570A.4 which governs the lien priority of an agricultural supply dealer.”
Oyens Feed & Supply, Inc. v. Primebank (2011) iowa · cites it 6× “Section 570A.4 requires dealers to comply with article 9 perfection requirements.”
Crooked Creek Corp. v. Primebank & Oyens Feed & Supply, Inc. (In Re Crooked Creek Corp.) (2010) ianb · cites it 10× “§ 570A.4, Iowa Code § 554.9308 (2). Oy-ens’s date of perfection is subsequent to the date of perfection of Primebank’s security interest in the same collateral.”
Farmers Cooperative Co. v. Ernst & Young Inc. (In re Petition of Big Sky Farms Inc.) (2014) ianb · cites it 13× “Iowa Code § 570A.4 (emphasis added). The Court recognized that perfection is critically important for an agricultural dealer because a dealer who is perfected obtains superpriority over other lenders for its hen.”
Schley v. Peoples Bank (In re Schley) (2017) ianb · cites it 2× “54 in feed it supplied from February 9 to March 11, 2010. The Iowa Supreme Court and this Court have interpreted Iowa Code chapter 570A in a number of cases, including an earlier decision in this case.”
White Front Feed & Seed, Division of Paul Lammers & Sons, Inc. v. State National Bank of Platteville (In Re Ramaker) (1990) ianb · cites it 2× “In addition to not seeking relief under § 364 of the Bankruptcy Code, White did not seek to *968 perfect a statutory lien under Iowa Code § 570A.4. White and Roeder argue that their positions in this matter should be enhanced by the fact that an original cash collateral order…”
Amended July 27, 2016 Oyens Feed & Supply, Inc. v. Primebank (2016) iowa · cites it 54× “9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
Schley v. Peoples Bank (In re Schley) (2014) ianb “On the record made in this case to date, the first financing statement would— at most — cover $43,317 in feed WFS claimed it supplied to Debtor. The second financing statement, filed after the sale of the pigs at issue here, would cover the 31-day period before June 30, 2010.”
Wells Fargo Bank, N.A. v. Innovative AG Service Co. (In re Highside Pork, L.L.C.) (2011) ianb · cites it 2× “” Iowa Code § 570A.4. In order to perfect their lien, the agricultural supply dealer “must file a financing statement in the office of the secretary of state as provided in section 554.”
Keast Enterprises Inc. (2020) iasb · cites it 6× “[A]n agricultural supply dealer's financing statement cannot perfect a lien under section 570A.4 for quantities of feed sold on credit after the statement is filed.”
Keast Enterprises Inc. (2020) iasb · cites it 6× “[A]n agricultural supply dealer's financing statement cannot perfect a lien under section 570A.4 for quantities of feed sold on credit after the statement is filed.”
— Iowa Code § 570A.4(1) — 4 cases
Oyens Feed & Supply, Inc. v. Primebank (2016) iowa “In order to perfect the" lien, the agricultural supply dealer must file a financing statement in the office of the secretary of state as provided in section 554.9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
Crooked Creek Corp. v. Primebank & Oyens Feed & Supply, Inc. (In Re Crooked Creek Corp.) (2010) ianb “§ 570A.4, Iowa Code § 554.9308 (2). Oy-ens’s date of perfection is subsequent to the date of perfection of Primebank’s security interest in the same collateral.”
Wells Fargo Bank, N.A. v. Tama Benton Cooperative (In Re Shulista) (2011) ianb “In Cross Motions for Summary Judgment, the parties seek an interpretation of Iowa Code § 570A.4 which governs the lien priority of an agricultural supply dealer.”
Amended July 27, 2016 Oyens Feed & Supply, Inc. v. Primebank (2016) iowa “9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
— Iowa Code § 570A.4(1)(6) — 1 case
Oyens Feed & Supply, Inc. v. Primebank (2016) iowa “In order to perfect the" lien, the agricultural supply dealer must file a financing statement in the office of the secretary of state as provided in section 554.9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
— Iowa Code § 570A.4(1)(b) — 2 cases
Oyens Feed & Supply, Inc. v. Primebank (2016) iowa “In order to perfect the" lien, the agricultural supply dealer must file a financing statement in the office of the secretary of state as provided in section 554.9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
Amended July 27, 2016 Oyens Feed & Supply, Inc. v. Primebank (2016) iowa “9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
— Iowa Code § 570A.4(2) — 9 cases
Oyens Feed & Supply, Inc. v. Primebank (2016) iowa “In order to perfect the" lien, the agricultural supply dealer must file a financing statement in the office of the secretary of state as provided in section 554.9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
Farmers Cooperative Co. v. Ernst & Young Inc. (In re Petition of Big Sky Farms Inc.) (2014) ianb “Iowa Code § 570A.4 (emphasis added). The Court recognized that perfection is critically important for an agricultural dealer because a dealer who is perfected obtains superpriority over other lenders for its hen.”
Schley v. Peoples Bank (In re Schley) (2014) ianb “On the record made in this case to date, the first financing statement would— at most — cover $43,317 in feed WFS claimed it supplied to Debtor. The second financing statement, filed after the sale of the pigs at issue here, would cover the 31-day period before June 30, 2010.”
Wells Fargo Bank, N.A. v. Tama Benton Cooperative (In Re Shulista) (2011) ianb “In Cross Motions for Summary Judgment, the parties seek an interpretation of Iowa Code § 570A.4 which governs the lien priority of an agricultural supply dealer.”
Amended July 27, 2016 Oyens Feed & Supply, Inc. v. Primebank (2016) iowa “9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
— Iowa Code § 570A.4(l)(6) — 1 case
Oyens Feed & Supply, Inc. v. Primebank (2016) iowa “In order to perfect the" lien, the agricultural supply dealer must file a financing statement in the office of the secretary of state as provided in section 554.9308 within thirty-one days after the date that the farmer purchases the agricultural supply.”
— Iowa Code § 570A.4(l)(b) — 1 case
Wells Fargo Bank, N.A. v. Tama Benton Cooperative (In Re Shulista) (2011) ianb “In Cross Motions for Summary Judgment, the parties seek an interpretation of Iowa Code § 570A.4 which governs the lien priority of an agricultural supply dealer.”
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