In this issue of Community Banker, the attorneys at Olson & Burns P.C. had another successful trip to Bismarck and the North Dakota Supreme Court, and once again generated case law beneficial to lenders. This case clarifies that lenders may first foreclose on real estate collateral and later foreclose on personal property collateral ( or vice versa) without concern for the rules of the deficiency judgment statutes so long as the real estate action doesn’t litigate personal property issues and the personal property action doesn’t litigate real property issues.

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