Tennessee Code Annotated
Tenn. Code Ann. § 47-9-625 (2026)
Remedies for secured party's failure to comply with chapter
✓ current as of May 2026
- (a)Judicial orders concerning noncompliance. If it is established that a secured party is not proceeding in accordance with this chapter, a court may order or restrain collection, enforcement, or disposition of collateral on appropriate terms and conditions.
- (b)Damages for noncompliance. Subject to subsections (c), (d), and (f), a person is liable for damages in the amount of any loss caused by a failure to comply with this chapter. Loss caused by a failure to comply may include loss resulting from the debtor's inability to obtain, or increased costs of, alternative financing.
- (c)Persons entitled to recover damages; statutory damages in consumer-goods transaction. Except as otherwise provided in § 47-9-628:
- (1) a person that, at the time of the failure, was a debtor, was an obligor, or held a security interest in or other lien on the collateral may recover damages under subsection (b) for its loss; and
- (2) if the collateral is consumer goods, a person that was a debtor or a secondary obligor at the time a secured party failed to comply with this part may recover for that failure in any event an amount not less than the credit service charge plus ten percent (10%) of the principal amount of the obligation or the time-price differential plus ten percent (10%) of the cash price.
- (d)Recovery when deficiency eliminated or reduced. A debtor whose deficiency is eliminated under § 47-9-626 may recover damages for the loss of any surplus. However, a debtor or secondary obligor whose deficiency is eliminated or reduced under § 47-9-626 may not otherwise recover under subsection (b) for noncompliance with this part relating to collection, enforcement, disposition, or acceptance.
- (e)Statutory damages: noncompliance with specified provisions. In addition to any damages recoverable under subsection (b), the debtor, consumer obligor, or person named as a debtor in a filed record, as applicable, may recover five hundred dollars ($500) in each case from a person that:
- (1) fails to comply with § 47-9-208;
- (2) fails to comply with § 47-9-209;
- (3) files a record that the person is not entitled to file under § 47-9-509(a) and fails to file a termination statement within ten (10) days after receiving an authenticated demand;
- (4) fails to cause the secured party of record to file or send a termination statement;
- (A) as required by § 47-9-513(a) within ten (10) days after receiving an authenticated demand or
- (B) as required by § 47-9-513 (c);
- (5) fails to comply with § 47-9-616(b)(1) and whose failure is part of a pattern, or consistent with a practice, of noncompliance; or
- (6) fails to comply with § 47-9-616(b)(2).
- (f)Statutory damages: noncompliance with § 47-9-210. A debtor or consumer obligor may recover damages under subsection (b) and, in addition, five hundred dollars ($500) in each case from a person that, without reasonable cause, fails to comply with a request under § 47-9-210. A recipient of a request under § 47-9-210 which never claimed an interest in the collateral or obligations that are the subject of a request under that section has a reasonable excuse for failure to comply with the request within the meaning of this subsection (f).
- (g)Limitation of security interest: noncompliance with § 47-9-210. If a secured party fails to comply with a request regarding a list of collateral or a statement of account under § 47-9-210, the secured party may claim a security interest only as shown in the list or statement included in the request as against a person that is reasonably misled by the failure.
Acts 2000, ch. 846, § 1.
Notes of Decisions
Cited in 12
cases, 2001–2018 · leading case: Auto Credit of Nashville v. Wimmer, 231 S.W.3d 896 (Tenn. 2007).
Auto Credit of Nashville v. Wimmer, 231 S.W.3d 896 (Tenn. 2007). “Tenn. Code Ann. § 47-9-625 (c)(2) (2001).”
Brunswick Acceptance Co., LLC v. MEJ, LLC, 292 S.W.3d 638 (Tenn. Ct. App. 2008). “Tenn.Code Ann. § 47-9-625(c)(2) (2001). Wimmer, 231 S.”
Regions Bank v. Thomas D. Thomas, 422 S.W.3d 550 (Tenn. Ct. App. 2013). “” Tenn.Code Ann. § 47-9-625(d). In an action arising from a transaction in which the amount of a deficiency or surplus is in issue, if a debtor places a secured party’s compliance with provisions relating to collection, enforcement, disposi *566 tion, or acceptance in issue, the…”
AmSouth Bank v. Trailer Source, Inc., 206 S.W.3d 425 (Tenn. Ct. App. 2006). “Whether the trial court erred in holding that Hyundai Translead lacked standing to claim damages under Section 47-9-625 of the Tennessee Commercial Code, solely because it was not entitled to notice of the proposed disposition of collateral under the terms of Section 47-9-611 of…”
R & J of Tennessee, Inc. v. Blankenship-Melton Real Est., Inc., 166 S.W.3d 195 (Tenn. Ct. App. 2004). “Tenn.Code Ann. § 47-9-625 (2003). We remand this case to the trial court and instruct the court to determine what damages, if any, Mr.”
Auto Credit of Nashville v. Melissa Wimmer (Tenn. Ct. App. 2006). “The buyer sought statutory damages under Tenn. Code Ann. § 47-9-625 arguing that the attempted notice was inadequate, and the trial court dismissed her counterclaim.”
R&J of Tennessee, Inc. v. Blankenship-Melton Real Est., Inc., & Walden Blankenship, Individually (Tenn. Ct. App. 2004). “Tenn. Code Ann. § 47-9-625 (2003). We remand this case to the trial court and instruct the court to determine what damages, if any, Mr.”
Regions Bank v. Thomas D. Thomas (Tenn. Ct. App. 2016). “See Tenn. Code Ann. § 47-9-625 (2013) (“A debtor whose deficiency is eliminated .”
Primary Residential Mortg., Inc. v. Sheri Baker (Tenn. Ct. App. 2018). “75 and statutory damages under Tennessee Code Annotated § 47-9-625(c) in the amount of $500. The court also awarded pre- and post-judgment interest.”
Fed. Express Credit Union v. Barry Lanier (Tenn. Ct. App. 2005). “See Tenn. Code Ann. § 47-9-625 (2003); R & J of Tennessee, Inc.”
Blake Burton v. Hardwood Pallets, Inc. (Tenn. Ct. App. 2001). “See T.C.A. § 47-9-625(c) (2001). Therefore, we find the plaintiffs’ argument to be without merit.”
Regions Bank v. Trailer Source (Tenn. Ct. App. 2010). “§ 47-9-625 provides that Hyundai is entitled to recover for “any loss caused by failure to comply with this chapter.”
Tenn. Code Ann. § 47-9-625(c): 2 cases
Blake Burton v. Hardwood Pallets, Inc. (Tenn. Ct. App. 2001). “See T.C.A. § 47-9-625(c) (2001). Therefore, we find the plaintiffs’ argument to be without merit.”
Primary Residential Mortg., Inc. v. Sheri Baker (Tenn. Ct. App. 2018). “75 and statutory damages under Tennessee Code Annotated § 47-9-625(c) in the amount of $500. The court also awarded pre- and post-judgment interest.”
Tenn. Code Ann. § 47-9-625(c)(2): 3 cases
Brunswick Acceptance Co., LLC v. MEJ, LLC, 292 S.W.3d 638 (Tenn. Ct. App. 2008). “Tenn.Code Ann. § 47-9-625(c)(2) (2001). Wimmer, 231 S.”
Regions Bank v. Thomas D. Thomas, 422 S.W.3d 550 (Tenn. Ct. App. 2013). “” Tenn.Code Ann. § 47-9-625(d). In an action arising from a transaction in which the amount of a deficiency or surplus is in issue, if a debtor places a secured party’s compliance with provisions relating to collection, enforcement, disposi *566 tion, or acceptance in issue, the…”
Auto Credit of Nashville v. Wimmer, 231 S.W.3d 896 (Tenn. 2007). “Tenn. Code Ann. § 47-9-625 (c)(2) (2001).”
Tenn. Code Ann. § 47-9-625(c)(l): 1 case
AmSouth Bank v. Trailer Source, Inc., 206 S.W.3d 425 (Tenn. Ct. App. 2006). “Whether the trial court erred in holding that Hyundai Translead lacked standing to claim damages under Section 47-9-625 of the Tennessee Commercial Code, solely because it was not entitled to notice of the proposed disposition of collateral under the terms of Section 47-9-611 of…”
Tenn. Code Ann. § 47-9-625(d): 1 case
Regions Bank v. Thomas D. Thomas, 422 S.W.3d 550 (Tenn. Ct. App. 2013). “” Tenn.Code Ann. § 47-9-625(d). In an action arising from a transaction in which the amount of a deficiency or surplus is in issue, if a debtor places a secured party’s compliance with provisions relating to collection, enforcement, disposi *566 tion, or acceptance in issue, the…”
Tenn. Code Ann. § 47-9-625(e)(3): 1 case
Primary Residential Mortg., Inc. v. Sheri Baker (Tenn. Ct. App. 2018). “75 and statutory damages under Tennessee Code Annotated § 47-9-625(c) in the amount of $500. The court also awarded pre- and post-judgment interest.”
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