UCC Article 9 directs the secured party to apply the proceeds from a disposition of collateral to the expenses of retaking, holding and preparing the collateral for disposition and then toward the obligation secured by the loan. 9-615. The debtor is liable for any deficiency after application of the proceeds. So, Bow Wow does in fact appear to owe the Bank the additional chow. One of my students found this case. Apparently, like me, he enjoys a little bit of Article 9 in action.