Texas Adopts the “Outstanding Balance” Method of Calculating the Deficiency or Surplus After Foreclosure of a Wraparound Deed of Trust: Summers v. Consolidated Capital Special Trust, 783 S.W.2d 580 (Tex. 1989)

Analyzes the Texas Supreme Court case of Summers v. Consolidated Capital Special Trust. The Texas Supreme Court adopted the outstanding balance approach of calculating deficiency or surplus after foreclosure of a wraparound deed of trust held that the sale price should be credited against the total outstanding indebtedness on the note.