784 P.2d 717 (Ariz. App. 1989); Glencoe State Bank v. Cole, 265 Ill. App. 158 (1932); Peoples Bank & Trust Co. v. L & T Developers, Inc., 434 So. 2d 699 (Miss. 1983); Home Federal Sav. and Loan Ass’n. v. Depass, 340 S.E.2d 545 (S.C. 1986). We first note that each of the cases cited by plaintiffs involve construction lending rather than commercial lending which, while certainly not dispositive, may more easily permit monitoring through on-site inspections. See Peoples Bank & Trust Co. v. L & T Developers, Inc., 434 So.2d 699 (Miss. 1983). Moreover, the existence of an implied duty on the part of a lender to a guarantor to monitor the borrower’s use of loan proceeds is far from universally recognized. See, e.g., Light v. Equitable Mortgage Resources, Inc., 383 S.E.2d 142 (Ga. App. 1989) (<HOLDING>). Indeed, Glencoe State Bank v. Cole, 265 Ill.
holding that a construction lender may voluntarily assume a duty to inspect the construction project for the borrowers benefit in addition to the lenders independent contractual right to inspect the project for its own exclusive benefit holding that federal express fee required by lender was a transaction imposed by the lender as incident to the extension of credit and needed to be disclosed within the finance charge holding lender loses right to a premium when it elects to accelerate the debt and declining to allow lender to avoid the consequences of its choice of acceleration holding that it was not improper for a lender to halt the proposed settlement and discounted payment of plaintiffs loan when the lender believed the loan would otherwise be paid in full holding that where lender undertook no duties for the benefit of guarantors lender owed guarantors no duty with regard to disbursement of construction loan proceeds to developer