Requirements for binding guaranty

An action may not be brought to charge an executor or administrator upon a special promise to answer damages out of his own estate, or to charge the defendant upon a special promise to answer for the debt, default, or miscarriage of another person, or to charge a person upon an agreement made upon consideration of marriage, or upon a contract or sale of real estate, of any interest in or concerning it, or upon an agreement that is not to be performed within one year from the making thereof, unless the agreement upon which the action is brought, or a memorandum or note thereof, is in writing, which need not state the consideration and signed by the party to be charged therewith or a person authorized by him. (DC ST § 28-3502)

The extension of credit to a debtor is sufficient consideration for a guaranty by a third party who benefits, no matter how directly, from the loan to the debtor. There is no requirement for new consideration for each new debt if a guaranty expressly covers all future debts of the borrower to the lender. Opton, Inc. v. FDIC, 647 A.2d 1126, 1133 (D.C. 1994)