In many ways, a foreclosure on collateral not only threatens a debtor with loss of property, but it presents risks to the secured party as well. Part 6 of Article 9 of the Uniform Commercial Code imposes a number of requirements on a secured party seeking to realize on collateral. Failure to abide by those requirements could result in loss to or even liability of the secured party under UCC Sections 9-625 and 9-626.

UCC Section 9-625(a) additionally empowers a court to enjoin a secured party from proceeding with a foreclosure if such creditor is not complying with those requirements. However, courts have not given 9-625(a) the deference that, at least in the view of the UCC Permanent Editorial Board (PEB), the drafters intended.