On September 11, 2015, three of Bryan Cave’s financial institution / banking litigators (Curtis Romig, Edwin Cook, and Leah Fiorenza McNeill) filed an amicus curiae brief on behalf of the Georgia Bankers Association in a case currently pending before the Georgia Supreme Court, PNC Bank, N.A v. Smith, Case No. S15Q1445.  The case is of great interest to banks operating in Georgia, as well as other states that reject the “single action” rule and allow pursuit of judgments after foreclosure.  The focus of the Supreme Court will be the Georgia Court of Appeals’ 2013 ruling in HWA Properties, Inc. v. Cmty. & S. Bank, 322 Ga. App. 877 (2013), holding that a lender was entitled to pursue a guarantor for any deficiency remaining on a debt after a foreclosure, regardless of whether the lender had confirmed the foreclosure sale, if the guaranty included language waiving all defenses to collection of