To be sure, receivers are rarely pursued in the residential foreclosure case, although sometimes it can be a good idea. For a helpful review of that particular subject, consult 1 Bergman on New York Mortgage Foreclosures §2.26 Receivership Primer: The Residential Case, LexisNexis, Matthew Bender (rev. 2022).

In the commercial case, though, the appointment of a receiver is always to be considered. Indeed, it is rarely neglected. (After all, most commercial cases involve income producing properties so that during the course of the foreclosure action, the borrower is collecting all the income, typically remitting none to the mortgage holder.)