Assume that Jane Doe leases an automobile from a General Motors dealer, pursuant to a lease contract under which Jane makes a cash security deposit. Under the lease, the lessor agrees to “refund” the deposit at the conclusion of the lease term in the event that Jane fully performs her obligations under the lease. Is this transaction governed by Article 9--i.e., has the lessor taken a “security interest” in Jane's cash deposit to secure Jane's obligations under the lease agreement?
R. Wilson Freyermuth, Are Security Deposits "Security Interests"? The Proper Scope of Article 9 and Statutory Interpretation in Consumer Class Actions, 68 Mo. L. Rev. 71 (2003)