Mich. Comp. Laws » Michigan Compiled Laws / Chapter 440 / Act 174 of 1962
Michigan Compiled Laws

Mich. Comp. Laws § 440.9204 (2026)

After-acquired property; future advances.

✓ current as of July 2026
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UNIFORM COMMERCIAL CODE


Act 174 of 1962


440.9204 After-acquired property; future advances.

Sec. 9204.

    (1) Except as otherwise provided in subsection (2), a security agreement may create or provide for a security interest in after-acquired collateral.

    (2) A security interest does not attach under a term constituting an after-acquired property clause to either of the following:

    (a) Consumer goods, other than an accession when given as additional security, unless the debtor acquires rights in them within 10 days after the secured party gives value.

    (b) A commercial tort claim.

    (3) A security agreement may provide that collateral secures, or that accounts, chattel paper, payment intangibles, or promissory notes are sold in connection with, future advances or other value, whether or not the advances or value are given pursuant to commitment.

History: 1962, Act 174, Eff. Jan. 1, 1964 ;-- Am. 1978, Act 369, Eff. Jan. 1, 1979 ;-- Am. 2000, Act 348, Eff. July 1, 2001

Notes of Decisions
Cited in 12 cases, 1973–2015 · leading case: Nat'l Bank v. Eames & Brown, Inc., 242 N.W.2d 412 (Mich. 1976).
Sort: Relevance Newest Treatment
Nat'l Bank v. Eames & Brown, Inc., 242 N.W.2d 412 (Mich. 1976). “MCLA 440.9204(1) says a security interest "cannot attach until * * * the debtor has rights in the collateral”.”
Yamaha Motor Corp., USA v. Tri-City Motors & Sports, Inc., 429 N.W.2d 871 (Mich. Ct. App. 1988). “, when there is an agreement that certain items are to secure payment or performance of an obligation, when value is given, and when the debtor acquires rights in the collateral, MCL 440.9204(1); MSA 19.9204(1). Second, the creditor must have taken all the applicable steps for…”
GMAC Bus. Credit, L.L.C. v. Ford Motor Co. (In Re H.S.A. II, Inc.), 271 B.R. 534 (Bankr. E.D. Mich. 2002). “II was merely a bailee. A security interest attaches to collateral when (1) the debtor has signed a security agreement describing the collateral, (2) value has been given, and (3) the debtor has “rights in the collateral.”
Thorp Fin. Corp. v. Ken Hodgins & Sons, 251 N.W.2d 614 (Mich. Ct. App. 1977). “The requirements of attachment were satisfied, MCLA 440.9204(1); MSA 19.9204(1) and the March 20, 1974 note incorporated by reference the 1971 security agreement into the 1974 loan.”
Hugo v. United States Ex Rel. Farmers Home Admin. (In Re Hugo), 50 B.R. 963 (Bankr. E.D. Mich. 1985). “§ 440.9204 (West 1985 Cumulative Annual Pocket Part).”
GMAC Bus. Credit, L.L.C. v. Ford Motor Co., 100 F. App'x 404 (6th Cir. 2004). “” Mich. Comp. Laws § 440.9204 (1). The first two requirements are clearly satisfied in this case.”
Litwiller Mach. & Mfg., Inc v. Nbd Alpena Bank, 457 N.W.2d 163 (Mich. Ct. App. 1990). “” MCL 440.9204(1); MSA 19.9204(1). The second requirement is not disputed in this case; the question is whether the compo *373 nents were part of Koss’ after-acquired inventory described in its security agreement with defendant, and, if so, whether Koss had sufficient rights in…”
Michigan Tractor & Mach. Co. v. Elsey, 549 N.W.2d 27 (Mich. Ct. App. 1996). “They argue that the modem trend is to recognize a continuing security interest in inventory and accounts receivable, even absent an after-acquired property clause. Plaintiff counters that a security agreement in after-acquired property can attach to such collateral only when the…”
New Prods. Corp. v. Tibble (In re Modern Plastics Corp.), 534 B.R. 723 (Bankr. W.D. Mich. 2015). “§ 440.9204(2)(b) (“[a] security interest does not attach under a term constituting an after-acquired property clause to .”
Sears, Roebuck & Co. v. Detroit Fed. Sav. & Loan Ass'n, 262 N.W.2d 831 (Mich. Ct. App. 1977). · cites it 2× “9108 and MCLA 440.9204[3]; MSA 19.9204[3]) give specific rights to a creditor to secure a debt with property not owned by the debtor at the time that the parties enter into a security agreement.”
Nat. Bank of Detroit v. Eames & Brown, Inc., 213 N.W.2d 573 (Mich. Ct. App. 1973). “9203, and MCLA 440.9204; MSA 19.9204. 5 See: MCLA 440.”
Eyde Constr. Co. v. Pub. Data Assocs., 6 B.R. 733 (W.D. Mich. 1980). ““Contract right” means any right to payment under a contract not yet earned by performance and not evidenced by an instrument or chattel paper. Former M.C.”
— Mich. Comp. Laws § 440.9204(1) — 6 cases
Nat'l Bank v. Eames & Brown, Inc., 242 N.W.2d 412 (Mich. 1976). “MCLA 440.9204(1) says a security interest "cannot attach until * * * the debtor has rights in the collateral”.”
Yamaha Motor Corp., USA v. Tri-City Motors & Sports, Inc., 429 N.W.2d 871 (Mich. Ct. App. 1988). “, when there is an agreement that certain items are to secure payment or performance of an obligation, when value is given, and when the debtor acquires rights in the collateral, MCL 440.9204(1); MSA 19.9204(1). Second, the creditor must have taken all the applicable steps for…”
GMAC Bus. Credit, L.L.C. v. Ford Motor Co. (In Re H.S.A. II, Inc.), 271 B.R. 534 (Bankr. E.D. Mich. 2002). “II was merely a bailee. A security interest attaches to collateral when (1) the debtor has signed a security agreement describing the collateral, (2) value has been given, and (3) the debtor has “rights in the collateral.”
Thorp Fin. Corp. v. Ken Hodgins & Sons, 251 N.W.2d 614 (Mich. Ct. App. 1977). “The requirements of attachment were satisfied, MCLA 440.9204(1); MSA 19.9204(1) and the March 20, 1974 note incorporated by reference the 1971 security agreement into the 1974 loan.”
Litwiller Mach. & Mfg., Inc v. Nbd Alpena Bank, 457 N.W.2d 163 (Mich. Ct. App. 1990). “” MCL 440.9204(1); MSA 19.9204(1). The second requirement is not disputed in this case; the question is whether the compo *373 nents were part of Koss’ after-acquired inventory described in its security agreement with defendant, and, if so, whether Koss had sufficient rights in…”
— Mich. Comp. Laws § 440.9204(2)(b) — 1 case
New Prods. Corp. v. Tibble (In re Modern Plastics Corp.), 534 B.R. 723 (Bankr. W.D. Mich. 2015). “§ 440.9204(2)(b) (“[a] security interest does not attach under a term constituting an after-acquired property clause to .”
— Mich. Comp. Laws § 440.9204(2)(d) — 1 case
Eyde Constr. Co. v. Pub. Data Assocs., 6 B.R. 733 (W.D. Mich. 1980). ““Contract right” means any right to payment under a contract not yet earned by performance and not evidenced by an instrument or chattel paper. Former M.C.”
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