Wash. Rev. Code » Title 61 · Chapter 61.24
Revised Code of Washington

Wash. Rev. Code § 61.24.060 (2026)

✓ current as of May 2026
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(1) The purchaser at the trustee's sale shall be entitled to possession of the property on the twentieth day following the sale, as against the borrower and grantor under the deed of trust and anyone having an interest junior to the deed of trust, including occupants who are not tenants, who were given all of the notices to which they were entitled under this chapter. The purchaser shall also have a right to the summary proceedings to obtain possession of real property provided in chapter 59.12 RCW.
(2) If the trustee elected to foreclose the interest of any occupant or tenant, the purchaser of tenant-occupied property at the trustee's sale shall provide written notice to the occupants and tenants at the property purchased in substantially the following form:
"NOTICE: The property located at . . . . . . was purchased at a trustee's sale by . . . . . . on . . . . . . (date).
1. If you are the previous owner or an occupant who is not a tenant of the property that was purchased, pursuant to RCW 61.24.060, the purchaser at the trustee's sale is entitled to possession of the property on . . . . . . (date), which is the twentieth day following the sale.
2. If you are a tenant or subtenant in possession of the property that was purchased, pursuant to RCW 61.24.146, the purchaser at the trustee's sale may either give you a new rental agreement OR give you a written notice to vacate the property in sixty days or more before the end of the monthly rental period."
(3) The notice required in subsection (2) of this section must be given to the property's occupants and tenants by both first-class mail and either certified or registered mail, return receipt requested.
[ 2009 c 292 s 10; 1998 c 295 s 8; 1967 c 30 s 2; 1965 c 74 s 6.]
Notes of Decisions
Cited in 45 cases (10 in the last 5 years), 1971–2026 · leading case: Laffranchi v. Lim, 190 P.3d 97 (Wash. Ct. App. 2008).
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Laffranchi v. Lim, 190 P.3d 97 (Wash. Ct. App. 2008). · cites it 4× “¶ 17 Laffranchi brought this action under RCW 61.24.060, which authorizes a purchaser at a trustee's sale to obtain possession of the purchased property using the summary proceedings in chapter 59.”
Laffranchi v. Lim, 146 Wash. App. 376 (Wash. Ct. App. 2008). · cites it 4× “¶17 Laffranchi brought this action under RCW 61.24.060, which authorizes a purchaser at a trustee’s sale to obtain possession of the purchased property using the summary proceedings in chapter 59.”
Excelsior Mortg. Equity Fund II, LLC v. Schroeder, 287 P.3d 21 (Wash. Ct. App. 2012). · cites it 2× “RCW 61.24.060(1). ¶4 Before borrowing from Excelsior, Mr.”
Sav. Bank v. Mink, 741 P.2d 1043 (Wash. Ct. App. 1987). · cites it 3× “The principal issue presented on this appeal is whether or not a formal notice to quit is required as a jurisdictional prerequisite to the unlawful detainer action.”
River Stone Holdings NW LLC, V Alice M. Lopez, 395 P.3d 1071 (Wash. Ct. App. 2017). “¶13 RCW 61.24.060(1) provides that after the trustee’s sale takes place, the purchaser is entitled to possession of the property after 20 days as against the borrower if the purchaser provided proper notices under the DTA.”
Rucker v. NovaStar Mortg., Inc., 311 P.3d 31 (Wash. Ct. App. 2013). “” RCW 61.24.060(1). ¶24 Here, as Rucker and April correctly point out, NovaStar’s entitlement to Rucker’s property depends on the existence of the trustee’s sale.”
Peoples Nat'l Bank v. Ostrander, 491 P.2d 1058 (Wash. Ct. App. 1971). · cites it 2× “Plaintiff commenced an unlawful detainer action on October 30, 1970, pursaunt to the provisions of RCW 61.24.060, to obtain possession of certain real property which had been purchased by plaintiff at a trustee’s sale on September 25, 1970.”
Fed. Nat'l Mortg. Ass'n v. Ndiaye, 353 P.3d 644 (Wash. Ct. App. 2015). “In turn, RCW 61.24.060(1) provides, in relevant part: The purchaser at the trustee’s sale shall be entitled to possession of the property on the twentieth day following the sale, as against the borrower and grantor under the deed of trust and anyone having an interest junior to…”
Koegel v. Prudential Mut. Sav. Bank, 752 P.2d 385 (Wash. Ct. App. 1988). “RCW 61.24.060. The act was designed *114 by the legislature to avoid time-consuming judicial foreclosure proceedings and to save substantial time and money to both the buyer and the lender.”
Udall v. T.D. Escrow Servs., Inc., 130 P.3d 908 (Wash. Ct. App. 2006). “RCW 61.24.060. ¶22 We reiterate that we must strictly apply and interpret the Act in favor of the borrower, which in this case is Brown, on whose behalf the hank instituted foreclosure procedures to satisfy his debt.”
Puget Sound Inv. Grp., Inc. v. Bridges, 963 P.2d 944 (Wash. Ct. App. 1998). “5 See RCW 61.24.060; RCW 61.30.120(7). 6 RCW 59.”
Selene RMOF II Reo Acquisitions II, LLC v. Ward (Wash. 2017). · cites it 18× “92967-0 that Selene had acquired its interest from LaSalle after foreclosure and that pursuant to RCW 61.24.060 (discussed below), the purchaser at a trustee's sale had a right to summary unlawful detainer proceedings to obtain possession of the property under chapter 59.”
Show all 45 citing cases →
— Wash. Rev. Code § 61.24.060(1) — 26 cases
Excelsior Mortg. Equity Fund II, LLC v. Schroeder, 287 P.3d 21 (Wash. Ct. App. 2012). “RCW 61.24.060(1). ¶4 Before borrowing from Excelsior, Mr.”
River Stone Holdings NW LLC, V Alice M. Lopez, 395 P.3d 1071 (Wash. Ct. App. 2017). “¶13 RCW 61.24.060(1) provides that after the trustee’s sale takes place, the purchaser is entitled to possession of the property after 20 days as against the borrower if the purchaser provided proper notices under the DTA.”
Rucker v. NovaStar Mortg., Inc., 311 P.3d 31 (Wash. Ct. App. 2013). “” RCW 61.24.060(1). ¶24 Here, as Rucker and April correctly point out, NovaStar’s entitlement to Rucker’s property depends on the existence of the trustee’s sale.”
Fed. Nat'l Mortg. Ass'n v. Ndiaye, 353 P.3d 644 (Wash. Ct. App. 2015). “In turn, RCW 61.24.060(1) provides, in relevant part: The purchaser at the trustee’s sale shall be entitled to possession of the property on the twentieth day following the sale, as against the borrower and grantor under the deed of trust and anyone having an interest junior to…”
Selene RMOF II Reo Acquisitions II, LLC v. Ward (Wash. 2017). “92967-0 that Selene had acquired its interest from LaSalle after foreclosure and that pursuant to RCW 61.24.060 (discussed below), the purchaser at a trustee's sale had a right to summary unlawful detainer proceedings to obtain possession of the property under chapter 59.”
— Wash. Rev. Code § 61.24.060(2) — 6 cases
Raymond Huisingh, Et Ux, V, Leon A. Lawson, Et Ux (Wash. Ct. App. 2024).
Guy Way & Zenaida Way v. John Choquer (Wash. Ct. App. 2016).
Dwa Investments Llc v. Marcel Maddox (Wash. Ct. App. 2018).
John Thornton v. Debra Fifer & Claudio Mosquera (Wash. Ct. App. 2018).
Christopher Honse & Sally Honse v. Patrice Clinton & Richard Sorrels (Wash. Ct. App. 2015).
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