In National Shawmut Bank of Boston v. New Amsterdam Cas. Co., 411 F.2d 843 (1st Cir. 1969), one of the seminal cases discussing a surety's right to remaining contract proceeds in light of a secured creditor's claim to the same funds, the court interpreted provisions of the Massachusetts Uniform Commercial Code ("UCC"). In that case, a general contractor entered into a construction contract with the U.S. Air Force, and applied for payment and performance bonds from the appellee surety. According to the contract's terms, the contractor assigned earned money from the contract to the surety; the surety, however, failed to record the assignment. The contractor also obtained a line of credit from the appellant bank, and assigned money earned under the same contract as security; the bank, however, did record its assignment pursuant to the requirements of Article 9 of the UCC. The contractor defaulted, and the surety stepped in and satisfactorily finished the project. Both the surety and the bank sought to satisfy their respective claims from the remaining funds. The court was squarely faced with the question of "to what extent, if any, does the doctrine of subrogation survive the passage of Article 9 of the UCC?" National Shawmut, 411 F.2d at 844. The court noted that equitable subrogation was an old concept rooted in equity. Id. The appellant bank, just like CDA, argued that the UCC was the sole law governing a surety's right to reimbursement from a limited pool of funds claimed by multiple parties, and therefore, any attempt to rely upon general principles of surety law promulgated prior to the passage of the code was incorrect. In response, the court began with an analysis of M.G.L.A. 1-103, which states that "unless displaced by the particular provisions of this chapter, the principles of law and equity . . . shall supplement its provisions." Id. Thus, the court found there would be no tension between equitable subrogation and the UCC unless a particular provision of the code modified those rights. Id. at 845. Next, the court analyzed M.G.L.A. 1-201(37), 9-102, 9-106, and 9-312 and concluded that none of those provisions conflicted with equitable subrogation, and resulted in a bank's right to contract proceeds superseding a surety's right to priority. Id. at 845-46. The court held that "'no provision of the Code (UCC) purports to affect the fundamental equitable doctrine of subrogation.'" Id. at 847. The court awarded the surety the remaining contract funds because the UCC's recording requirement did not apply to sureties and the code did not supplant principles of equitable subrogation. Id. at 849.