Supreme Court of Missouri

The Central Trust Bank v. Barbara Branch and Alexis Branch

September 13, 2022

Summary

The Court reversed the judgment denying the Bank a deficiency judgment and remanded. It held that the Bank complied with the statutory requirement to send a post-sale explanation by mailing it via certified mail to the Branches' last known address, without needing to prove receipt or make additional attempts after the mail was returned. It also held that a dealers-only auction was not a public sale, so the Bank's pre-sale notice describing a private sale satisfied the statutory disclosure requirements.