Revised Code of Washington
Wash. Rev. Code § 61.24.110 (2026)
Reconveyance by trustee
✓ current as of May 2026
Find cases:
SyfertCases citing this section
WA-LEGapp.leg.wa.gov
JustiaTitle on Justia
CornellLII Search
CasesGoogle Scholar
(1) The trustee of record shall reconvey all or any part of the property encumbered by the deed of trust to the person entitled thereto on written request of the beneficiary, or upon satisfaction of the obligation secured and written request for reconveyance made by the beneficiary or the person entitled thereto.
(2) If the beneficiary fails to request reconveyance within the sixty-day period specified under RCW 61.16.030 and has received payment as specified by the beneficiary's demand statement, a title insurance company or title insurance agent as licensed and qualified under chapter 48.29 RCW, a licensed escrow agent as defined in RCW 18.44.011, or an attorney admitted to practice law in this state, who has paid the demand in full from escrow, upon receipt of notice of the beneficiary's failure to request reconveyance, may, as agent for the person entitled to receive reconveyance, in writing, submit proof of satisfaction and request the trustee of record to reconvey the deed of trust.
(3)(a) If the trustee of record is unable or unwilling to reconvey the deed of trust within one hundred twenty days following payment to the beneficiary as prescribed in the beneficiary's demand statement, a title insurance company or title insurance agent as licensed and qualified under chapter 48.29 RCW, a licensed escrow agent as defined in RCW 18.44.011, or an attorney admitted to practice law in this state may record with each county auditor where the original deed of trust was recorded a notarized declaration of payment. The notarized declaration must: (i) Identify the deed of trust, including original grantor, beneficiary, trustee, loan number if available, and the auditor's recording number and recording date; (ii) state the amount, date, and name of the beneficiary and means of payment; (iii) include a declaration that the payment tendered was sufficient to meet the beneficiary's demand and that no written objections have been received; and (iv) be titled "declaration of payment."
(b) A copy of the recorded declaration of payment must be sent by certified mail to the last known address of the beneficiary and the trustee of record not later than two business days following the date of recording of the notarized declaration. The beneficiary or trustee of record has sixty days from the date of recording of the notarized declaration to record an objection. The objection must: (i) Include reference to the recording number of the declaration and original deed of trust, in the records where the notarized declaration was recorded; and (ii) be titled "objection to declaration of payment." If no objection is recorded within sixty days following recording of the notarized declaration, any lien of the deed of trust against the real property encumbered must cease to exist.
Notes of Decisions
Cited in 9
cases (5 in the last 5 years), 1988–2024 · leading case: Fitch v. Buffalo Fed. Sav. & Loan Ass'n, 751 P.2d 1309 (Wyo. 1988).
Fitch v. Buffalo Fed. Sav. & Loan Ass'n, 751 P.2d 1309 (Wyo. 1988). “§ 86-770(2) (1987) (deeds of trust on noncommercial property); Wash. Rev. Code § 61.24.110 (Cum.Supp. 1987) (deeds of trust).”
Revocable Living Trust of Strand v. Wel-Co Grp., Inc., 86 P.3d 818 (Wash. Ct. App. 2004). “RCW 61.24.110. In sum, Strand did not impair Wel-Co’s suretyship status by reconveying the condo deed of trust to the Browns.”
Us Bank, Respondent-cross v. Kreg Kendall, Appellant-cross (Wash. Ct. App. 2019). “" Kendall claims the court erred because he recorded a Declaration of Payment in accordance with RCW 61.24.110(3), which extinguished the lien.”
Carpenter v. Fawcett (W.D. Wash. 2024). “The parties agree that, pursuant to RCW 61.24.110, Plaintiffs were required to satisfy their debt before requesting reconveyance of the 9 deed of trust.”
Revocable Living Trust of Strand v. Wel-co Grp., Inc., 86 P.3d 818 (Wash. Ct. App. 2004). “RCW 61.24.110. In sum, Strand did not impair Wel-Co's suretyship status by reconveying the condo deed of trust to the Browns.”
The Hanover Ins. Co. v. Intrepid Law Grp. LLC (W.D. Wash. 2021). “010 (relating to fraud in the solicitation of the 15 sale of securities); breach of contract for failure to pay the returns promised in the 16 Executive Summary; breach of fiduciary duty for executing the reconveyance without 17 their knowledge or consent; violation of RCW…”
Schoenberger v. PNC Bank (W.D. Wash. 2021). “Nothing in 12 any of the cases Schoenberger cites supports his claim, or his conduct, which is a 13 violation of the Deed of Trust Act, RCW 61.24.110(1). 14 If Schoenberger believed in good faith that his efforts were something other than 15 an attempted “gotcha,” there would be…”
The Hanover Ins. Co. v. Intrepid Law Grp. LLC (W.D. Wash. 2021). “010 (relating to fraud in the solicitation of the sale of 7 securities); breach of contract for failure to pay the returns promised in the Executive 8 Summary; breach of fiduciary duty for reconveying the Property without their knowledge 9 or consent; violation of RCW 61.24.110…”
Monroy v. Real Time Resolutions Inc (W.D. Wash. 2022). “MERS argues that “[i]t is not the disputed Assignment [of the deed of trust] that 22 empowers a beneficiary to pursue foreclosure under Washington law, but possession of the note 23 24 25 4 See also RCW 61.24.110(1) (providing “[t]he trustee of record shall reconvey all or any…”
— Wash. Rev. Code § 61.24.110(1) — 2 cases
Schoenberger v. PNC Bank (W.D. Wash. 2021). “Nothing in 12 any of the cases Schoenberger cites supports his claim, or his conduct, which is a 13 violation of the Deed of Trust Act, RCW 61.24.110(1). 14 If Schoenberger believed in good faith that his efforts were something other than 15 an attempted “gotcha,” there would be…”
Monroy v. Real Time Resolutions Inc (W.D. Wash. 2022). “MERS argues that “[i]t is not the disputed Assignment [of the deed of trust] that 22 empowers a beneficiary to pursue foreclosure under Washington law, but possession of the note 23 24 25 4 See also RCW 61.24.110(1) (providing “[t]he trustee of record shall reconvey all or any…”
— Wash. Rev. Code § 61.24.110(3) — 1 case
Us Bank, Respondent-cross v. Kreg Kendall, Appellant-cross (Wash. Ct. App. 2019). “" Kendall claims the court erred because he recorded a Declaration of Payment in accordance with RCW 61.24.110(3), which extinguished the lien.”
— Wash. Rev. Code § 61.24.110(3)(a) — 1 case
Us Bank, Respondent-cross v. Kreg Kendall, Appellant-cross (Wash. Ct. App. 2019). “" Kendall claims the court erred because he recorded a Declaration of Payment in accordance with RCW 61.24.110(3), which extinguished the lien.”
— Wash. Rev. Code § 61.24.110(3)(b) — 1 case
Us Bank, Respondent-cross v. Kreg Kendall, Appellant-cross (Wash. Ct. App. 2019). “" Kendall claims the court erred because he recorded a Declaration of Payment in accordance with RCW 61.24.110(3), which extinguished the lien.”
Annotations are extracted automatically from the opinions in the
Syfert caselaw corpus and ranked by authority, recency, and
treatment. Dots show Syfertize treatment of the citing case itself.