A large number of commercial loans expected to default in the near future could lead many lenders to put the subject properties into receivership. But, as Polsinelli shareholders Brett Anders and James Billingsley write, courts have not historically been very deferential to lenders’ subsequent requests to foreclose on those properties if needed. In this article, Anders and Billingsley say Texas-based lenders and their legal advisors need to be aware of this issue, and endeavor to nudge the courts towards a more deferential approach, relying on the guidance of First Southern.