Filed September 22, 2009
UCC §9-313(c) contemplates not only notice by a secured party to a third party holding collateral, but also express authentication of an acknowledgement that the person is holding possession of the collateral for the secured party’s benefit. (See UCC §9-313(c), Official Comment 4; 810 ILCS 5/9-313(c).) Neither the Participation Agreement nor the Sale Agreement satisfies these requirements.