Massachusetts General Laws

Mass. Gen. Laws ch. 255B, § 20A (2026)

Default; enforcement; notice; accelerated payment; curing of default

✓ current as of July 2026
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Section 20A. (a) An agreement of the parties in a retail installment contract defining default is enforceable only to the extent that the default is material and consists of the buyer's failure to make one or more installments as required by the agreement; or the occurrence of an event which substantially impairs the value of the collateral.

(b) After a default by a buyer under a consumer credit transaction, the secured creditor may not bring an action against the buyer or proceed against the collateral until he gives the buyer the notice described in this section. The notice so required shall be deemed to be delivered when delivered to the debtor or when mailed to the debtor at the debtor's address last known to the creditor. If a buyer cures a default after receiving notice and again defaults, the creditor shall give another notice before bringing an action or proceeding against the collateral with respect to the subsequent default, but no notice is required in connection with a subsequent default if, within the period commencing on the date of the consumer credit transaction subject to this section and the date of the subsequent default, the debtor has cured a default after notice three or more times.

(c) The notice shall be in writing and shall be given to the buyer ten days or more after the default. The notice shall conspicuously state the rights of the buyer upon default in substantially the following form:—

The heading shall read:—''Rights of Defaulting Buyer under the Massachusetts Motor Vehicle Installment Sales Act.'' The body of the notice shall read:—''You may cure your default in (describe transaction in a manner enabling buyer to identify it) by paying to (name and address of creditor) (amount due) before (date which is at twenty-one days after notice is mailed). If you pay this amount within the time allowed, you are no longer in default and may continue on with the transaction as though no default had occurred.

If you do not cure your default by the date stated above, the said creditor may sue you to obtain a judgment for the amount of the debt or, if applicable, may take possession of the collateral.

If the creditor takes possession of the collateral, if any, you may get it back by paying the full amount of your debt plus any reasonable expenses incurred by the said creditor if you make the required payment within twenty days after he takes possession.''

(d) During the twenty-one day period after delivery of the notice required by this section the creditor may not because of that default accelerate the unpaid balance of the obligation, bring action against the buyer, or proceed against the collateral.

(e) Unless the secured creditor has first notified the buyer that he has elected to accelerate the unpaid balance of the obligation because of default, brought action against the buyer, or proceeded against the collateral, the buyer may cure a default consisting of a failure to pay money by tendering the amount of all unpaid sums due at the time of tender, without acceleration, plus any unpaid delinquency or deferral charges. Such a cure shall restore the buyer to his rights under the agreement as though the defaults had not occurred subject to the provisions of subsection (b).

Notes of Decisions
Cited in 18 cases (1 in the last 5 years), 1963–2023 · leading case: Williams v. Am. Honda Fin. Corp., 98 N.E.3d 169 (Mass. 2018).
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Williams v. Am. Honda Fin. Corp., 98 N.E.3d 169 (Mass. 2018). · cites it 8× “5 The Legislature enacted the current provisions in G. L. c. 255B, §§ 20A and 20B, in 1973. St.”
Wilder v. Toyota Fin. Servs. Americas Corp., 764 F. Supp. 2d 249 (D. Mass. 2011). · cites it 10× “(# 19 at 2) Second, the defendants argue that the plaintiffs claims for “breach of contract and breach of implied covenant of good faith and fair dealing must also fail because they are likewise based on the alleged violations of Mass.”
In Re Pluta, 200 B.R. 740 (Bankr. D. Mass. 1996). · cites it 3× “Rather, the Debtor’s right to cure was determined under the Contract and, pursuant to Mass.Gen.L. ch. 255B, § 20A(d) and (e). Those rights do not in-elude the right to cure after a secured creditor repossesses its collateral.”
New England Merchants Nat'l Bank v. McPherson, 58 Mass. App. Dec. 106 (Mass. Dist. Ct., App. Div. 1976). · cites it 16× “In addition the defendant filed a declaration in set-off seeking to recover in three counts: Count I under G.L.c. 255B, §20A (E) in that the plaintiff failed to comply with c.”
Lopes v. Fafama Auto Sales, 76 U.C.C. Rep. Serv. 2d (West) 192 (Mass. Dist. Ct., App. Div. 2011). · cites it 2× “255B, §2 not only voided the contract, but also prevented Fafama from repossessing the vehicle under G.Lc. 255B, §§20A and 20B. l.The trial judge did not err in ruling that, assuming G.”
U.S. Trust Co. v. Carreiro, 2000 Mass. App. Div. 159 (Mass. Dist. Ct., App. Div. 2000). · cites it 3× “The crux of the motion to dismiss was that the plaintiffs complaint was filed to collect on a deficiency after repossession of an automobile pursuant to G.L.c. 255B, Sections 20A and B, and that the plaintiffs complaint was fatally flawed in that it did not specifically plead…”
Abbott Motors, Inc. v. Ralston, 28 Mass. App. Dec. 35 (Mass. Dist. Ct., App. Div. 1964). · cites it 2× “No notice of the time and place of the sale was given to the defendant, and no affidavit of purchase as provided for by G. L. c. 255B, §20A was obtained or filed.”
Cadle Co. v. Zottoli, 6 Mass. L. Rptr. 8 (Mass. Super. Ct. 1996). · cites it 3× “Zottoli’s arguments that the sale was wrongful are merely a repetition of his prior arguments about G.L.c. 255B, §§20A and 20B. 10 Inasmuch as that statute did not apply to this transaction, failure to comply with it does not make the foreclosure sale “wrongful.”
Kagan v. Ford Motor Credit Co., 400 N.E.2d 276 (Mass. App. Ct. 1980). · cites it 3× “When Schifano bought his car, G. L. c. 255B, § 20A, as amended through St.”
Johnson v. Wilmington Sales, Inc., 364 N.E.2d 1291 (Mass. App. Ct. 1977). “The plaintiff’s claims under G. L. c. 255B, § 20A(B), as in effect prior to St.”
Dellorusso v. PNC Bank, N.A. (Mass. App. Ct. 2020). · cites it 3× “4 provisions of [G. L. c. 255B, §§ 20A and 20B]." G. L. c.”
James v. Ally Fin. Inc. (D. Mass. 2023). · cites it 2× “Gen. Laws c. 255B. Under Massachusetts law, the rights and duties of debtors and creditors after a default on a retail installment contract are governed by the Vehicle Retail Installment Sale Act (RISA), Mass.”
Show all 18 citing cases →
— Mass. Gen. Laws ch. 255B, § 20A(B) — 1 case
Johnson v. Wilmington Sales, Inc., 364 N.E.2d 1291 (Mass. App. Ct. 1977). “The plaintiff’s claims under G. L. c. 255B, § 20A(B), as in effect prior to St.”
— Mass. Gen. Laws ch. 255B, § 20A(a) — 1 case
Lopes v. Fafama Auto Sales, 76 U.C.C. Rep. Serv. 2d (West) 192 (Mass. Dist. Ct., App. Div. 2011). “255B, §2 not only voided the contract, but also prevented Fafama from repossessing the vehicle under G.Lc. 255B, §§20A and 20B. l.The trial judge did not err in ruling that, assuming G.”
— Mass. Gen. Laws ch. 255B, § 20A(d) — 1 case
In Re Pluta, 200 B.R. 740 (Bankr. D. Mass. 1996). “Rather, the Debtor’s right to cure was determined under the Contract and, pursuant to Mass.Gen.L. ch. 255B, § 20A(d) and (e). Those rights do not in-elude the right to cure after a secured creditor repossesses its collateral.”
— Mass. Gen. Laws ch. 255B, § 20A(e) — 2 cases
Wilder v. Toyota Fin. Servs. Americas Corp., 764 F. Supp. 2d 249 (D. Mass. 2011). “(# 19 at 2) Second, the defendants argue that the plaintiffs claims for “breach of contract and breach of implied covenant of good faith and fair dealing must also fail because they are likewise based on the alleged violations of Mass.”
In Re Pluta, 200 B.R. 740 (Bankr. D. Mass. 1996). “Rather, the Debtor’s right to cure was determined under the Contract and, pursuant to Mass.Gen.L. ch. 255B, § 20A(d) and (e). Those rights do not in-elude the right to cure after a secured creditor repossesses its collateral.”
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