Jerome Road, LLC v. First Citizens Bank & Trust Co., 312 Ga. App. 583

Jerome Road, LLC and Been appeal a foreclosure-sale confirmation order from Fulton County.
They contend the order lacks findings of fact and conclusions of law.
They did not request findings before the judgment; post-judgment request was made 15 days after the order.
First Citizens Bank petitioned for confirmation; after a hearing, the trial court entered a two-paragraph order confirming the sale and noting conformity to law and a stated fair market value of $850,500, enabling a deficiency judgment.
Appellants moved for findings 15 days after the order; no resolving order appears in the record; they appealed thereafter.
The issue presented is whether confirmation orders must contain findings and conclusions when not requested before judgment; the decision overruled earlier precedent to the extent it required such findings absent a prior request.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must a foreclosure-confirmation order include findings of fact and conclusions of law when no prior request was made?	Jerome Road and Been rely on older cases mandating findings.	First Citizens Bank contends post-judgment requests allow court discretion; findings are not mandatory absent timely request.	Under OCGA 9-11-52(a) and (c), findings are mandatory only if requested before judgment; the order need not include them here.

Lanier v. Citizens State Bank, 186 Ga. App. 395 (1988) ((367 S.E.2d 585) (overruled to extent inconsistent with statute))
Mathis v. Citizens DeKalb Bank, 157 Ga. App. 693 (1981) ((278 S.E.2d 500) (pre-1987 statute))
Pruitt v. First Nat. Bank of Habersham County, 142 Ga. App. 100 (1977) ((235 S.E.2d 617) (pre-1987 statute))
Poor v. Leader Fed. Bank &c., 221 Ga. App. 889 (1996) ((473 S.E.2d 563) (statutory interpretation of 9-11-52))