Revised Code of Washington
Wash. Rev. Code § 19.36.110 (2026)
✓ current as of May 2026
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A credit agreement is not enforceable against the creditor unless the agreement is in writing and signed by the creditor. The rights and obligations of the parties to a credit agreement shall be determined solely from the written agreement, and any prior or contemporaneous oral agreements between the parties are superseded by, merged into, and may not vary the credit agreement. Partial performance of a credit agreement does not remove the agreement from the operation of this section.
[ 1990 c 211 s 3.]
Notes of Decisions
Cited in 14
cases (1 in the last 5 years), 1998–2021 · leading case: Frontier Bank v. Bingo Investments, Appellant's, 361 P.3d 230 (Wash. Ct. App. 2015).
Frontier Bank v. Bingo Investments, Appellant's, 361 P.3d 230 (Wash. Ct. App. 2015). “Washington Statute of Frauds—Credit Agreements: RCW 19.36.110 ¶45 As a threshold matter, Union Bank argues that the credit agreement statute of frauds bars considering the documents on which the guarantors rely for their affirmative defenses.”
Cowlitz Bank v. Leonard, 254 P.3d 194 (Wash. Ct. App. 2011). “Cowlitz Bank moved for summary judgment and moved to strike Leonard’s affirmative defenses and counterclaims on grounds that RCW 19.36.110 bars the enforcement of any oral agreements not contained in the written loan documents.”
D. Ryan & Rhonda Patrick, Apps v. Wells Fargo, 385 P.3d 165 (Wash. Ct. App. 2016). “RCW 19.36.110; Cowlitz Bank v. Leonard, 162 Wn.”
Union Bank, N.a., Resp. v. John T. Blanchard, Apps., 378 P.3d 191 (Wash. Ct. App. 2016). “RCW 19.36.110 (emphasis added). *355 ¶39 A “credit agreement” is defined as an agreement, promise, or commitment to lend money, to otherwise extend credit, to forbear with respect to the repayment of any debt or the exercise of any remedy, to modify or amend the terms under…”
W. Farm Serv., Inc. v. Olsen, 59 P.3d 93 (Wash. Ct. App. 2002). “RCW 19.36.110 addresses the enforceability of such agreements: A credit agreement is not enforceable against the creditor unless the agreement is in writing and signed by the creditor.”
Robinett v. Opus Bank, 987 F. Supp. 2d 1099 (W.D. Wash. 2013). “RCW 19.36.110. There is a further prerequisite to enforcement of this Statute of Frauds provision: The creditor shall give notice to the other party on a separate document or incorporated into one or more of the documents relating to a credit agreement.”
First Nat'l Bank Of Omaha v. David T. Gilchrist (Wash. Ct. App. 2016). “RCW 19.36.110. But RCW 19.36.110 does not apply to a promise, agreement, undertaking, document, or commitment relating to a credit card.”
Piper v. JP Morgan Chase Bank NA (W.D. Wash. 2021). “See 12 Wash. Rev. Code § 19.36.110 . Accordingly, this claim is DISMISSED with prejudice.”
Richard L. Harwood v. Wells Fargo Bank, N.A. (Wash. Ct. App. 2013). “Wells Fargo Bank agreements appearing in RCW 19.36.110, which clearly applies. Although the trial court did not base its decision upon RCW 19.”
Consol. Servs., Inc. v. KeyBank Nat'l Ass'n, 29 F. Supp. 2d 942 (N.D. Ind. 1998). “1991) (approved 1990); Wash.Rev.Code Ann. §§ 19.36.110 to .140 (West Supp.”
Black Diamond Dev. Co, Apps/x-res v. Union Bank N.a., Resp/x-app (Wash. Ct. App. 2018). “Union Bank had no obligation to accept less 9 RCW 19.36.110. -6- No. 76079-3-1/ 7 than the full amount owed.”
Gbc Int'l Bank v. Cory & Geneanne Burke (Wash. Ct. App. 2013). “7 RCW 19.36.110 provides that "[a] credit agreement is not enforceable against the creditor unless the agreement is in writing and signed by the creditor.”
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