44-14-161(a) governs actions between a defendant debtor and the SBA. United States v. Dismuke, 616 F.2d 755, 759 (5th Cir.1980); see also United States v. Irby, 618 F.2d 352, 355 (5th Cir.1980) (applying Mississippi real property law to determine reasonableness and validity of foreclosure sale by SBA under guaranty agreement). Furthermore, § 44-14-161(a) applies to both primary debtors and guarantors; an action for the balance remaining on a note following a foreclosure sale against a guarantor rather than the primary debtor is still an action for a deficiency judgment under the statute and is barred if no confirmation was obtained. United States v. Dismuke, 616 F.2d 755, 759 (5th Cir.1980); see also First National Bank & Trust Co. v. Kunes, 230 Ga. 888, 889, 199 S.E.2d 776, 778 (1973) (<HOLDING>). Thus, if the foreclosure sale in the case sub
holding that guarantors and sureties are  debtors within the meaning of the georgia confirmation statute immediately upon the default on the promissory notes holding that in order to establish liability under the ada the plaintiff must demonstrate that the defendant was an employer within the meaning of the statute holding that order denying confirmation of plan became final when upon being notified that the debtors did not intend to seek confirmation of an alternate plan the court dismissed their case holding that a debtors right to strip off a wholly unsecured lien is conditioned on the debtors obtaining confirmation of and performing under a chapter 13 plan that meets all of the statutory requirements rather than on a debtors discharge holding that workers compensation awards remained property of the estate despite confirmation of the debtors plans where the confirmation orders specifically provided that property of the estate did not vest in the debtor until the completion of the plan