Foreclosure

===Australia and New Zealand===
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Foreclosure has been prohibited by law in New Zealand for well over a century. Instead the mortgagee realises the security through sale, the exercise of the power of sale also being regulated by statute.

In both of these countries statutory reform has altered the manner in which real property dealings are conducted. What is termed a "mortgage" is a legal interest that is registered against the fee simple title of the property. Since in both countries, the [[Torrens title]] system of land registration is used, being registered as proprietor or as a mortgagee creates an indefeasible interest (unless the acquisition of the registration was by land transfer fraud). The mortgagee therefore never holds the fee simple, and there is a statutory process for initiating and conducting a mortgagee sale in the event that the mortgagor defaults. In New Zealand, as in England, say, the land title database is now electronic so there are no paper "title documents".