Louisiana Revised Statutes & Codes

La. Rev. Stat. § 6:1122 (2026)

A debtor shall not maintain an action on a credit agreement unless the agreement is in writing, expresses consideration, sets forth the relevant terms and conditions, and is signed by the creditor and the debtor.

✓ current as of May 2026
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§1122.  Credit agreements to be in writing

A debtor shall not maintain an action on a credit agreement unless the agreement is in writing, expresses consideration, sets forth the relevant terms and conditions, and is signed by the creditor and the debtor.

Acts 1989, No. 531, §1.

Notes of Decisions
Cited in 63 cases (10 in the last 5 years), 1991–2024 · leading case: King v. Par. Nat'l Bank, 885 So. 2d 540 (La. 2004).
King v. Par. Nat'l Bank, 885 So. 2d 540 (La. 2004). · cites it 11× “R.S. 6:1122 is inapplicable to the bad faith claims against the appraisers and appraisal company since these claims are outside the parameters of the statute.”
Fortenberry v. Hibernia Nat. Bank, 852 So. 2d 1221 (La. Ct. App. 2003). · cites it 10× “R.S. 6:1122, and in dismissing Ms. Bryant in spite of specific allegations of her intentional conduct.”
EPCO Carbon Dioxide Prods., Inc. v. JP Morgan Chase Bank, NA, 467 F.3d 466 (5th Cir. 2006). · cites it 2× “” La.Rev. Stat. § 6:1122 (2005). The purpose of the statute is “to prevent potential borrowers from bringing claims against lenders based upon oral agreements;” its effect is to bar “all actions for damages arising from oral credit agreements, regardless of the legal theory of…”
Woodlands Dev., L.L.C. v. Regions Bank, 83 So. 3d 147 (La. Ct. App. 2011). · cites it 6× “Regions countered that there is no written credit agreement between Regions and plaintiffs, as is required by LSA-R.S. 6:1122, that purports to release plaintiffs from their obligations under their guarantees and the First and Second Amendments to the Forbearance Agreement,…”
Bernard v. Iberia Bank, 832 So. 2d 355 (La. Ct. App. 2002). · cites it 12× “R.S. 6:1122 requires that credit agreements be in writing.”
Guzzardo-Knight v. Cent. Progressive Bank, 762 So. 2d 1243 (La. Ct. App. 2000). · cites it 10× “R.S. 6:1122. We hold that La. R.S. 6:1122 precludes plaintiffs from recovering damages against the lender under the asserted causes of action that are all based on the existence of an oral credit agreement, and we sustain the exception of no cause of action.”
Keenan v. Donaldson, Lufkin & Jenrette, Inc., 529 F.3d 569 (5th Cir. 2008). · cites it 3× “There is a conceptual clash in this case between common understandings of the terms “creditor” and “debtor,” and DLJ’s view — accepted by the district court— about the statutory definitions.”
Regions Bank v. Cabinet Works, L.L.C., 92 So. 3d 945 (La. Ct. App. 2012). · cites it 3× “R.S. 6:1122, which states, “A debtor shall not maintain an action on a credit agreement unless the agreement is in writing, expresses consideration, sets forth the relevant terms and conditions, and is signed by the creditor and the debtor.”
Hancock Bank of Louisiana v. 3429 H, LLC, 184 So. 3d 274 (La. Ct. App. 2016). · cites it 2× “R.S. 6:1122. 9 Similarly, Schmidt bdid not allege the existence of any fiduciary duty, created by a written agency agreement, owed by bank employee, Pender, or bank attorney, LeG-ros.”
Whitney Bank v. SMI Companies Global, Inc., 949 F.3d 196 (5th Cir. 2020). “to take certain actions, such as entering into a new credit agreement” and therefore must satisfy, inter alia, the writing and signature requirements of La. Rev. Stat. § 6:1122. Moreover, the court in BizCapital was not interpreting the portions of the LCAS at issue here,…”
St. Landry Homestead Fed. Sav. Bank v. Vidrine, 118 So. 3d 470 (La. Ct. App. 2013). · cites it 3× “R.S. 6:1122. Credit agreements to be in writing A debtor shall not maintain an action on a credit agreement unless the agreement is in writing, expresses consideration, sets forth the relevant terms and conditions, and is signed by the creditor and the debtor.”
Vance v. Fed. Nat'l Mortg. Ass'n, 235 So. 3d 1263 (La. Ct. App. 2017). · cites it 2× “R.S, 6:1122, part of the Louisiana Credit Agreement Statute, provides: A debtor shall not maintain an action on a credit agreement unless the agreement.”
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