News & Analysis as of

Guarantors

King & Spalding

New York Appellate Court Reverses Denial of Bank’s Summary Judgment Motion for Amounts Owed Under Cancelled Credit Agreement

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On November 26, 2025, the New York Appellate Division, Second Department reversed a trial court order denying Plaintiff Citibank, N.A.’s motion for summary judgment for breach of contract, breach of a personal guaranty, and...more

King & Spalding

Southern District of New York Rules That Lender’s Alleged Bad-Faith Failure to Engage with Borrowers’ Proposed Collateral Sales...

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On December 16, 2025, the U.S. District Court for the Southern District of New York granted summary judgment on liability in favor of lender Jasper Lake Ventures Two LLC, holding that its alleged refusal to engage with...more

Davidoff Hutcher & Citron LLP

How Chapter 11 Can Resolve Your Personal Guarantees and EIDL Loans

If you’re a restaurant owner in New York carrying COVID-era EIDL debt and personal guarantees that feel impossible to pay, I have good news: there are real, practical pathways to resolve these obligations—often for far less...more

Patton Sullivan Brodehl LLP

The “Sham Guaranty” Defense is Not Easy to Establish

Under California anti-deficiency law, borrowers enjoy robust protections.  Guarantors — not so much.  The statutory protections afforded to borrowers cannot be waived, while for guarantors, they can be (and almost always are)...more

Davidoff Hutcher & Citron LLP

The Restaurant Letter of Intent: Locking in Your Deal Terms Before the Lawyers Fight Over the Lease

The Letter of Intent (LOI) is where you set the business deal. The lease is where the lawyers argue over the details. If the LOI is vague or one-sided, you’ll either overpay in the lease or burn a ton of time and fees trying...more

Barnea Jaffa Lande & Co.

Performance Guarantees in Israeli NOP 38 Projects: Not Every Bank Guarantee Covers Developer Insolvency

Apartment owners in NOP 38 projects tend to mistakenly believe the guarantees issued to them by developers provide full safety nets, guaranteeing their rights in any case, even if the developer encounters financial...more

Genova Burns LLC

Clarity Over Convenience: New Jersey Supreme Court Provides Lessons for Companies Seeking Personal Guarantees

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Oftentimes when dealing with a small business, especially a new one with limited credit history, it is wise to obtain a personal guarantee from the company’s principal. ...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

New York Court of Appeals Rules on Good Guy Guaranty; Highlights the Need for Precision in Drafting Commercial Agreements

On October 21, 2025, in 1995 CAM LLC v. West Side Advisors, LLC, the New York Court of Appeals delivered a ruling concerning a guarantor’s liability under a “good guy” guaranty....more

Offit Kurman

Enforcing Guaranties Quickly in New York Courts

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New York law provides creditors with a powerful tool to pursue collection on a written guaranty on an expedited track. CPLR 3213 allows a creditor to serve a summons along with a motion for summary judgment — bypassing the...more

King & Spalding

New York Appellate Court Rejects Defendants’ Argument That Revenue Purchase Agreement Was Usurious Loan

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On July 25, 2025, a New York intermediate appellate court reversed a grant of summary judgment in plaintiff’s favor on its breach of contract and related breach of guaranty claims, concluding that while the agreement was a...more

King & Spalding

Southern District of Mississippi Rejects Argument That Broad Waiver Provisions in Guaranty Agreements Are Unconscionable

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On September 16, 2025, the U.S. District Court for the Southern District of Mississippi declined to dismiss a claim for breach of guaranty agreements, rejecting the defendants’ argument that the contracts are “so...more

King & Spalding

Ohio Supreme Court Says Creditors Do Not Have an Affirmative Duty to Disclose Facts That Materially Increase Risk to a Surety

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On August 20, 2025, the Ohio Supreme Court clarified the obligations of lenders and guarantors in arm’s-length financial transactions and declined to adopt the obligations set out by Section 124(1) of the Restatement (First)...more

Stark & Stark

New York Court of Appeals Narrows Landlord Protections Under “Good Guy” Guaranties

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The New York Court of Appeals issued a major decision reshaping how commercial “good guy” guaranties are interpreted. In 1995 CAM LLC v. West Side Advisors, LLC, the Court held that a personal guarantor’s liability ends when...more

Cole Schotz

Welcomed Clarity for New York Commercial Landlords and Tenants: Court of Appeals Rules on “Good-Guy” Guaranties

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The New York Court of Appeals’ recent decision in 1995 CAM LLC v. West Side Advisors LLC provides long-awaited guidance on how so-called “good-guy” guaranties operate in commercial leasing. The question in this case was...more

Bricker Graydon Wyatt LLP

Why Choose Ohio Law to Govern Your Commercial Loan Documents?

Earlier this year, my colleague Sam Lind made a compelling case for incorporating your business in Ohio—highlighting not only legal advantages but also some timeless thoughts on college football. Today, I pose a similar...more

Lathrop GPM

New Jersey Federal Court Grants Licensor’s Motion for Partial Summary Judgment and Finds Licensee and Guarantors Liable for...

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In Days Inns Worldwide, Inc. v. 4200 Rose Hospitality LLC, 2025 WL 2450755 (D.N.J. Aug. 25, 2025), Days Inns brought claims for contractual indemnification pursuant to a license agreement, common law/equitable...more

Brownstein Hyatt Farber Schreck

Colorado Court of Appeals Expands Fee Recovery Rights in Lease Enforcement Disputes

The Colorado Court of Appeals recently clarified the scope of contractual fee-shifting provisions in lease agreements in an opinion, which may have broader implications for businesses with lease agreements or other similar...more

Kohrman Jackson & Krantz LLP

Ohio Supreme Court Clarifies No Duty of Disclosure in Guaranty Agreements

In August 2025, the Supreme Court of Ohio issued its decision in Huntington National Bank v. Schneider providing important guidance on the obligations of lenders in guaranty and suretyship relationships. The Court rejected...more

Bricker Graydon Wyatt LLP

Lenders Rejoice - Ohio Supreme Court Saves The Day On Guaranties

In 2024, we alerted you to a decision out of the First Appellate District of Ohio (The Huntington National Bank v. Schneider, C-230072 (December 29, 2023)), where the Court was asked to review a grant of summary judgment in...more

Vorys, Sater, Seymour and Pease LLP

Ohio Supreme Court Ruling Clarifies Whether Banks Owe a Duty to Loan Guarantors

The Ohio Supreme Court overturned the First Appellate District’s ruling in Huntington National Bank v. Schneider (Case No. 2024-0208), clarifying when banks must disclose material information to loan guarantors. In a case...more

Hogan Lovells

English Supreme Court holds that the Etridge protocol applies to hybrid loan transactions

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Lenders in the retail market will be familiar with the Etridge protocol, which (in summary) requires them to ensure that the guarantor of a loan must first obtain independent legal advice, in order to minimise the risk that...more

Walkers

Privy Council clarifies secured party’s duty when realising security

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The Privy Council has clarified that the duty of care to "obtain the best price reasonably obtainable" in the sale of secured collateral does not require a secured party to improve an asset before sale to obtain the best...more

Amundsen Davis LLC

Guarantors vs. Co-Borrowers: Avoiding Pitfalls in Loan Structuring

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In commercial lending, the decision to designate a party as a guarantor or co-borrower is more than a technicality—it can significantly impact a lender’s ability to enforce a loan. Mislabeling a guarantor as a co-borrower,...more

Cadwalader, Wickersham & Taft LLP

From Big Ben to the Big Apple, June 2025 - Westminster Meets Wall Street: U.S. Law Considerations in English Law Facilities...

Fund finance is and always has been by nature a cross border enterprise. While there are a number of lenders that we represent in the United States that lend to funds exclusively organized in the U.S.– typically in Delaware –...more

Farrell Fritz, P.C.

When Additional Obligations Don’t Derail CPLR 3213: Commercial Division Clarifies the Test

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Commercial loan documents are notoriously complex, packed with financial reporting requirements, compliance covenants, and collateral maintenance obligations.  For practitioners seeking the expedited relief of CPLR 3213’s...more

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