Tennessee Code Annotated

Tenn. Code Ann. § 66-25-101 (2026)

Requirements for record of release

✓ current as of May 2026

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(a) When a debt secured by a mortgage, deed of trust, or by lien retained in a deed of conveyance of land or bill of sale, or other instrument, has been fully paid or satisfied, the mortgagee, transferee, or assignee of the mortgagee or the legal holder of the debt secured by deed of trust or lien, who has received payment or satisfaction of the debt, must satisfy the record by a formal deed of release.

(b) In any county having a population of not less than thirty-two thousand six hundred (32,600) nor more than thirty-two thousand seven hundred (32,700), according to the 1980 federal census or any subsequent federal census the record may be satisfied by entry on the margin of the record of the mortgage, deed of trust, deed or other instrument.

Acts 1907, ch. 473, § 1; Shan., § 3704a1; mod. Code 1932, § 8070; T.C.A. (orig. ed.), § 64-2501; Acts 1988, ch. 636, § 12; 1990, ch. 902, § 3.

Notes of Decisions

Cited in 7 cases (2 in the last 5 years), 1985–2022 · leading case: Regions Bank v. Bric Constructors, LLC, f/k/a Bric Contractors, LLC, & Patricia McIntosh, 380 S.W.3d 740 (Tenn. Ct. App. 2011).

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Regions Bank v. Bric Constructors, LLC, f/k/a Bric Contractors, LLC, & Patricia McIntosh, 380 S.W.3d 740 (Tenn. Ct. App. 2011). · cites it 5× “The resolution, however, depends on the trial court’s assessment of the credibility of the witnesses. 28 . That statute provides that when a debt “has been fully paid or satisfied,” the debt holder "must satisfy the record by a formal deed of release.”

United Am. Bank of Memphis v. Gardner, 706 S.W.2d 639 (Tenn. Ct. App. 1985). · cites it 2× “Counsel for UABM asserts T.C.A. § 66-25-101 is a statutory basis for the creation of a duty upon Mid-South and Gardner and the violation of the statute renders one liable in tort.”

TRW-Title Ins. v. Stewart Title Guar. Co., 832 S.W.2d 344 (Tenn. Ct. App. 1991). · cites it 2× “Tennessee Code Annotated, Section 66-25-101(a) (Supp.1991) provides: When a debt secured by a mortgage, deed of trust, or by lien retained in a deed of conveyance of land or bill of sale, or other instrument, has been fully paid or satisfied, the mortgagee, transferee, or…”

James Keith Eudaley v. U.S. Bank Nat'l Ass'n (Tenn. Ct. App. 2022). · cites it 5× “See generally Tenn. Code Ann. §§ 66-25-101 to -215 (2022).”

Blackthorn House, LLC v. First Volunteer Bank (Tenn. Crim. App. 2022). · cites it 4× “-9- Tenn. Code Ann. § 66-25-101 (a). If a debt has been fully paid or satisfied, and a mortgagee does not release the lien, then section 66-25-102 comes into play: (a) If the holder of any debt secured by real property situated in this state fails to enter a proper release of…”

Flatiron Acquisition Veh., LLC v. CSE Mortg. LLC (S.D.N.Y. 2020). · cites it 3× “Tenn. Code Ann. § 66-25-101 (a). This statute “requires .”

Vinings Bank v. Homeland Cmty. Bank (Tenn. Ct. App. 2019). · cites it 2× “” Tenn. Code Ann. § 66-25-101 (a) (2015). Under Tennessee Code Annotated § 66-25-102, if the mortgagee fails to enter a “proper release of record after having been fully paid,” the party that made the payment may request in writing that the mortgagee enter the release.”

— Tenn. Code Ann. § 66-25-101(a) — 3 cases

Regions Bank v. Bric Constructors, LLC, f/k/a Bric Contractors, LLC, & Patricia McIntosh, 380 S.W.3d 740 (Tenn. Ct. App. 2011). “The resolution, however, depends on the trial court’s assessment of the credibility of the witnesses. 28 . That statute provides that when a debt “has been fully paid or satisfied,” the debt holder "must satisfy the record by a formal deed of release.”

TRW-Title Ins. v. Stewart Title Guar. Co., 832 S.W.2d 344 (Tenn. Ct. App. 1991). “Tennessee Code Annotated, Section 66-25-101(a) (Supp.1991) provides: When a debt secured by a mortgage, deed of trust, or by lien retained in a deed of conveyance of land or bill of sale, or other instrument, has been fully paid or satisfied, the mortgagee, transferee, or…”

James Keith Eudaley v. U.S. Bank Nat'l Ass'n (Tenn. Ct. App. 2022). “See generally Tenn. Code Ann. §§ 66-25-101 to -215 (2022).”

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