The Tennessee Supreme Court has determined that reasonable notification does not require a creditor to verify actual receipt of the notice of a foreclosure sale under the Uniform Commercial Code, thus overturning a Tennessee Court of Appeals decision that we reported in our Spring 2007 newsletter, Auto Credit of Nashville v. Melissa Wimmer (Tenn. 2007). The court determined that notification sent via certified mail was reasonable even if the debtor never received the notification. To impose on the creditor the burden of verifying, in every instance, the actual receipt of notice would place an unreasonable burden on the creditor, thus making secured transactions unduly cumbersome.