Michigan Compiled Laws

Mich. Comp. Laws § 440.9504 (2026)

Indication of collateral.

✓ current as of July 2026

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UNIFORM COMMERCIAL CODE

Act 174 of 1962

440.9504 Indication of collateral.

Sec. 9504.

A financing statement sufficiently indicates the collateral that it covers if the financing statement provides 1 of the following:

(a) A description of the collateral pursuant to section 9108.

(b) An indication that the financing statement covers all assets or all personal property.

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 22 cases, 1970–2011 · leading case: Fodale v. Waste Mgmt. of Michigan, Inc, 718 N.W.2d 827 (Mich. Ct. App. 2006).

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Fodale v. Waste Mgmt. of Michigan, Inc, 718 N.W.2d 827 (Mich. Ct. App. 2006). · cites it 14× “However, both the former MCL 440.9504(1) and the current MCL 440.9610(1) state that after default a secured party "may sell, lease, license, or otherwise dispose of any or all of the collateral.”

Michigan Nat'l Bank v. Marston, 185 N.W.2d 47 (Mich. Ct. App. 1970). · cites it 20× “The trial court further determined that the actions of the bank in obtaining title to the car and in attempting to sell it were commercially reasonable under the provisions of the Uniform Commercial Code, MCLA § 440.9504 et seq. (Stat Ann 1964 Rev § 19.”

Wilson Leasing Co. v. Seaway Pharmacal Corp., 220 N.W.2d 83 (Mich. Ct. App. 1974). · cites it 12× “[3] MCLA 440.9504(1)(a); MSA 19.9504(1)(a). [4] MCLA 440.”

Prime Fin. Servs. LLC v. Vinton, 761 N.W.2d 694 (Mich. Ct. App. 2008). · cites it 3× “See MCL 440.9504(1); cf. MCL 440.9610(1) (2001).”

In Re Andersen, 50 B.R. 137 (Bankr. W.D. Mich. 1985). · cites it 9× “Mich.Comp.Laws § 440.9504 sets forth the rights and duties of creditors and debtors upon disposition of collateral after default.”

Roan v. Murray, 556 N.W.2d 893 (Mich. Ct. App. 1996). · cites it 2× “Defendant will then have twenty-one days to object in writing, in which case plaintiff must dispose of the vehicle in a commercially reasonable manner and account to defendant for any surplus.”

Wattles v. Agelastos, 183 N.W.2d 906 (Mich. Ct. App. 1970). · cites it 4× “It was not intended as a foreclosure sale of secured collateral under MCLA § 440.9504 (Stat Ann 1964 Rev § 19.9504).”

United States v. Champion Sprayer Co., 500 F. Supp. 708 (E.D. Mich. 1980). · cites it 2× “Michigan’s Uniform Commercial Code, MCL 440.9504, describes in pertinent part the manner in which the disposition of collateral must be made: “Disposition of the collateral may be made by public or private proceedings and may be made by way of 1 or more contracts.”

Gorham v. Denha, 258 N.W.2d 196 (Mich. Ct. App. 1977). · cites it 2× “9506, and MCLA 440.9504; MSA 19.9504. Costs to plaintiff.”

Emmons v. Easter, 233 N.W.2d 239 (Mich. Ct. App. 1975). · cites it 2× “The secured party may apply the excess to satisfy certain additional expenses, MCLA 440.9504(1); MSA 19.9504(1), but the record, in this case, is barren of evidence exactly indicating what expenses the Easters incurred by repossession and sale.”

Honor State Bank v. Timber Wolf Constr. Co., 391 N.W.2d 442 (Mich. Ct. App. 1986). · cites it 2× “MCL 440.9504(1); MSA 19.9504(1). Subsection (2) of § 9-504 provides that the secured party must account to the debtor for any surplus resulting from the disposition of the collateral, and, unless otherwise agreed, the debtor is liable for any deficiency.”

Boyd v. NBD Bank (In Re Thomas), 231 B.R. 8 (Bankr. W.D. Mich. 1999). · cites it 2× “, a secured party’s disposition of the collateral “discharges the security interest under which [the disposition] is made-” Mich.Comp.Laws Ann. § 440.9504(4). It follows that, at the time of the commencement of this action, NBD no longer held a security interest that could be…”

Show all 22 citing cases →

— Mich. Comp. Laws § 440.9504(1) — 4 cases

Prime Fin. Servs. LLC v. Vinton, 761 N.W.2d 694 (Mich. Ct. App. 2008). “See MCL 440.9504(1); cf. MCL 440.9610(1) (2001).”

Fodale v. Waste Mgmt. of Michigan, Inc, 718 N.W.2d 827 (Mich. Ct. App. 2006). “However, both the former MCL 440.9504(1) and the current MCL 440.9610(1) state that after default a secured party "may sell, lease, license, or otherwise dispose of any or all of the collateral.”

Emmons v. Easter, 233 N.W.2d 239 (Mich. Ct. App. 1975). “The secured party may apply the excess to satisfy certain additional expenses, MCLA 440.9504(1); MSA 19.9504(1), but the record, in this case, is barren of evidence exactly indicating what expenses the Easters incurred by repossession and sale.”

Honor State Bank v. Timber Wolf Constr. Co., 391 N.W.2d 442 (Mich. Ct. App. 1986). “MCL 440.9504(1); MSA 19.9504(1). Subsection (2) of § 9-504 provides that the secured party must account to the debtor for any surplus resulting from the disposition of the collateral, and, unless otherwise agreed, the debtor is liable for any deficiency.”

— Mich. Comp. Laws § 440.9504(1)(a) — 1 case

Wilson Leasing Co. v. Seaway Pharmacal Corp., 220 N.W.2d 83 (Mich. Ct. App. 1974). “[3] MCLA 440.9504(1)(a); MSA 19.9504(1)(a). [4] MCLA 440.”

— Mich. Comp. Laws § 440.9504(1)(b) — 1 case

Wilson Leasing Co. v. Seaway Pharmacal Corp., 220 N.W.2d 83 (Mich. Ct. App. 1974). “[3] MCLA 440.9504(1)(a); MSA 19.9504(1)(a). [4] MCLA 440.”

— Mich. Comp. Laws § 440.9504(2) — 5 cases

Michigan Nat'l Bank v. Marston, 185 N.W.2d 47 (Mich. Ct. App. 1970). “The trial court further determined that the actions of the bank in obtaining title to the car and in attempting to sell it were commercially reasonable under the provisions of the Uniform Commercial Code, MCLA § 440.9504 et seq. (Stat Ann 1964 Rev § 19.”

Roan v. Murray, 556 N.W.2d 893 (Mich. Ct. App. 1996). “Defendant will then have twenty-one days to object in writing, in which case plaintiff must dispose of the vehicle in a commercially reasonable manner and account to defendant for any surplus.”

Wattles v. Agelastos, 183 N.W.2d 906 (Mich. Ct. App. 1970). “It was not intended as a foreclosure sale of secured collateral under MCLA § 440.9504 (Stat Ann 1964 Rev § 19.9504).”

— Mich. Comp. Laws § 440.9504(3) — 10 cases

Wilson Leasing Co. v. Seaway Pharmacal Corp., 220 N.W.2d 83 (Mich. Ct. App. 1974). “[3] MCLA 440.9504(1)(a); MSA 19.9504(1)(a). [4] MCLA 440.”

In Re Andersen, 50 B.R. 137 (Bankr. W.D. Mich. 1985). “Mich.Comp.Laws § 440.9504 sets forth the rights and duties of creditors and debtors upon disposition of collateral after default.”

Jones v. Morgan, 228 N.W.2d 419 (Mich. Ct. App. 1975).

In Re Bluestone Est., 329 N.W.2d 446 (Mich. Ct. App. 1982).

— Mich. Comp. Laws § 440.9504(4) — 1 case

Boyd v. NBD Bank (In Re Thomas), 231 B.R. 8 (Bankr. W.D. Mich. 1999). “, a secured party’s disposition of the collateral “discharges the security interest under which [the disposition] is made-” Mich.Comp.Laws Ann. § 440.9504(4). It follows that, at the time of the commencement of this action, NBD no longer held a security interest that could be…”

— Mich. Comp. Laws § 440.9504(l)(a) — 3 cases

Wilson Leasing Co. v. Seaway Pharmacal Corp., 220 N.W.2d 83 (Mich. Ct. App. 1974). “[3] MCLA 440.9504(1)(a); MSA 19.9504(1)(a). [4] MCLA 440.”

Citizens Nat'l Bank v. Mayes, 350 N.W.2d 809 (Mich. Ct. App. 1984).

— Mich. Comp. Laws § 440.9504(l)(b) — 1 case

Wilson Leasing Co. v. Seaway Pharmacal Corp., 220 N.W.2d 83 (Mich. Ct. App. 1974). “[3] MCLA 440.9504(1)(a); MSA 19.9504(1)(a). [4] MCLA 440.”

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