Judicial foreclosure action is a proceeding in which a mortgagee, a trustee or another lienholder on property requests a court- supervised sale of the property to cover the unpaid balance of a delinquent debt.  Nonjudicial foreclosure is the process of selling real property under a power of sale in a mortgage or deed of trust that is in default. In such a foreclosure, however, the lender is unable to obtain a deficiency judgment, which makes some title insurance companies reluctant to issue a policy.