Vermont § 626 - § 9—626.

§ 626. § 9—626.

• Action in which deficiency or surplus is in issue (a) In an action arising from a transaction, other than a consumer transaction, in which
  the amount of a deficiency or surplus is in issue, the following rules apply: (1) A secured party need not prove compliance with the provisions of this part relating
  to collection, enforcement, disposition, or acceptance unless the debtor or a secondary
  obligor places the secured party’s compliance in issue. (2) If the secured party’s compliance is placed in issue, the secured party has the burden
  of establishing that the collection, enforcement, disposition, or acceptance was conducted
  in accordance with this part. (3) Except as otherwise provided in section 9—628 of this title, if a secured party fails to prove that the collection, enforcement, disposition,
  or acceptance was conducted in accordance with the provisions of this part relating
  to collection, enforcement, disposition, or acceptance, the liability of a debtor
  or a secondary obligor for a deficiency is limited to an amount by which the sum of
  the secured obligation, expenses, and attorney’s fees exceeds the greater of: (A) the proceeds of the collection, enforcement, disposition, or acceptance; or (B) the amount of proceeds that would have been realized had the noncomplying secured
  party proceeded in accordance with the provisions of this part relating to collection,
  enforcement, disposition, or acceptance. (4) For purposes of subdivision (3)(B) of this subsection, the amount of proceeds that
  would have been realized is equal to the sum of the secured obligation, expenses,
  and attorney’s fees unless the secured party proves that the amount is less than that
  sum. (5) If a deficiency or surplus is calculated under subsection 9—615(f) of this title, the debtor or obligor has the burden of establishing that the amount of proceeds
  of the disposition is significantly below the range of prices that a complying disposition
  to a person other than the secured party, a person related to the secured party, or
  a secondary obligor would have brought. (b) The limitation of the rules in subsection (a) of this section to transactions other
  than consumer transactions is intended to leave to the court the determination of
  the proper rules in consumer transactions. The court may not infer from that limitation
  the nature of the proper rule in consumer transactions and may continue to apply established
  approaches. (Added 1999, No. 106 (Adj. Sess.), § 2, eff. July 1, 2001.)