Revised Code of Washington

Wash. Rev. Code § 11.98.014 (2026)

✓ current as of May 2026

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Except as required by a statute other than this title, a trust need not be evidenced by a trust instrument, but the creation of an oral trust and its terms may be established only by clear, cogent, and convincing evidence.

[ 2011 c 327 s 19.]

Notes:

Application—Effective date—2011 c 327: See notes following RCW 11.103.020.

Notes of Decisions

Cited in 2 cases, 2013–2017 · leading case: Mele v. Mele (In Re Mele), 501 B.R. 357 (9th Cir. BAP 2013).

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Mele v. Mele (In Re Mele), 501 B.R. 357 (9th Cir. BAP 2013). “) Finally, RCW § 11.98.014, entitled “Trust creation — Oral trusts,” provides that, “Except as required by a statute other than this title, a trust need not be evidenced by a trust instrument, but the creation of an oral trust and its terms may be established only by clear,…”

In re Breast Cancer Prevention Fund, 574 B.R. 193 (Bankr. W.D. Wash. 2017). “A corporation has the capacity to take and hold property in trust and act as trustee.”

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