A Secured Creditor's Right to Collect a Deficiency Judgment under UCC Section 9-504: A Need to Remedy the Impasse

A secured creditor's right to collect a deficiency judgment under Uniform Commercial Code (UCC) section 9-5041 has recently been called most 'controversial remedy' found in the code.2 The controversy, and hence the nonuniform opinions of the courts and commentators, centers around the availability of damages to the debtor under section 9-507(l)3 where the question raised is as follows: if the debtor has a claim for damages under