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La. Rev. Stat. § 6:1123 (2026)

Actions not considered agreements

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§1123.  Actions not considered agreements

A.  The following actions shall not give rise to a claim that a new credit agreement is created, unless the agreement satisfies the requirements of R.S. 6:1122:

(1)  The rendering of financial or other advice by a creditor to a debtor.

(2)  The consultation by a creditor with a debtor.

(3)  The agreement of a creditor to take or not to take certain actions, such as entering into a new credit agreement, forbearing from exercising remedies under a prior credit agreement, or extending installments due under a prior credit agreement.

B.  A credit agreement shall not be implied from the relationship, fiduciary, or otherwise, of the creditor and the debtor.

Acts 1989, No. 531, §1.

Notes of Decisions
Cited in 18 cases (6 in the last 5 years), 1997–2024 · leading case: King v. Par. Nat'l Bank, 885 So. 2d 540 (La. 2004).
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King v. Par. Nat'l Bank, 885 So. 2d 540 (La. 2004). · cites it 5× “R.S. 6:1123, entitled "Actions not considered agreements," provides: A.”
Whitney Bank v. SMI Companies Global, Inc., 949 F.3d 196 (5th Cir. 2020). “This is unlike SMI’s claims, which involve a debtor suing a bank on an oral agreement to make changes to a loan—the type of claim that falls squarely within La. Rev. Stat. § 6:1123 as an “agreement of a creditor .”
St. Landry Homestead Fed. Sav. Bank v. Vidrine, 118 So. 3d 470 (La. Ct. App. 2013). · cites it 2× “R.S. 6:1123. Actions not considered agreements A.”
Bernard v. Iberia Bank, 832 So. 2d 355 (La. Ct. App. 2002). · cites it 2× “R.S. 6:1123 states: A. The following actions shall not give rise to a claim that a new credit agreement is created, unless the agreement satisfies the requirements of R.”
Fortenberry v. Hibernia Nat. Bank, 852 So. 2d 1221 (La. Ct. App. 2003). “R.S. 6:1123 The following actions shall not give rise to a claim that a new credit agreement is created, unless the agreement satisfies the requirements of R.”
Hibernia Nat. Bank v. CONTRACTOR'S EQUIP., 804 So. 2d 760 (La. Ct. App. 2001). “R.S. 6:1123 provides as follows: A. The following actions shall not give rise to a claim that a new credit agreement is created, unless the agreement satisfies the requirements of R.”
Ultra Fabricators, Inc. v. MC BANK, 724 So. 2d 210 (La. Ct. App. 1998). “R.S. 6:1123 provides as follows: A. The following actions shall not give rise to a claim that a new credit agreement is created, unless the agreement satisfies the requirements of R.”
Schwegmann Bank & Trust Co. v. Dunne, 693 So. 2d 349 (La. Ct. App. 1997). · cites it 2× “R.S. 6:1123. That statute provides, in pertinent part, that the agreement of a creditor "to take or not to take certain actions, such as .”
McCain v. J.P Morgan Mortg. Acquisition Corp., No. 2:20-cv-00987 (E.D. La. May 19, 2021). · cites it 4× “160 On a motion for summary judgment, the court considered La. Rev. Stat. § 6:1123, which states: A.”
Brokenburn, Inc. v. Cross Keys Bank & Bradley Bridges, 362 So. 3d 1031 (La. Ct. App. 2023). · cites it 4× “R.S. 6:1123, et seq., the Louisiana Credit Agreement Statute (“LCAS”), as the CRA was not enforceable as a credit agreement.”
Johnson v. Regions Bank, No. 2:20-cv-00533 (E.D. La. July 1, 2020). · cites it 3× “Multiple courts have held that the LCA does not “render[] a financial institution immune from any and all liability arising from its business operations, including business operations that occur outside of the parameters of a credit agreement as defined in La R.”
Plummer v. EverBank, 195 So. 3d 693 (La. Ct. App. 2016). · cites it 2× “R.S. 6:1123 then provides, in pertinent part, that the following actions: .”
Show all 18 citing cases →
La. Rev. Stat. § 6:1123(A): 1 case
Plummer v. EverBank, 195 So. 3d 693 (La. Ct. App. 2016). “R.S. 6:1123 then provides, in pertinent part, that the following actions: .”
La. Rev. Stat. § 6:1123(A)(3): 3 cases
King v. Par. Nat'l Bank, 885 So. 2d 540 (La. 2004). “R.S. 6:1123, entitled "Actions not considered agreements," provides: A.”
Brokenburn, Inc. v. Cross Keys Bank & Bradley Bridges, 362 So. 3d 1031 (La. Ct. App. 2023). “R.S. 6:1123, et seq., the Louisiana Credit Agreement Statute (“LCAS”), as the CRA was not enforceable as a credit agreement.”
Deutsch Bank Nat'l Trust Co. v. Maylois Conerly Price, 401 So. 3d 95 (La. Ct. App. 2024).
La. Rev. Stat. § 6:1123(B): 4 cases
King v. Par. Nat'l Bank, 885 So. 2d 540 (La. 2004). “R.S. 6:1123, entitled "Actions not considered agreements," provides: A.”
St. Landry Homestead Fed. Sav. Bank v. Vidrine, 118 So. 3d 470 (La. Ct. App. 2013). “R.S. 6:1123. Actions not considered agreements A.”
Brokenburn, Inc. v. Cross Keys Bank & Bradley Bridges, 362 So. 3d 1031 (La. Ct. App. 2023). “R.S. 6:1123, et seq., the Louisiana Credit Agreement Statute (“LCAS”), as the CRA was not enforceable as a credit agreement.”
Deutsch Bank Nat'l Trust Co. v. Maylois Conerly Price, 401 So. 3d 95 (La. Ct. App. 2024).
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