A recent judicial decision has precluded the Farmers Home Administration from employing nonjudicial foreclosure proceedings in some states. Characteristics of FmHA loans and borrowers suggest that a potential "hold up" problem exists whereby borrowers may cause the value of their mortgaged properties to diminish below the outstanding balance of the loan. Empirical results of a survey show that the preclusion of nonjudicial foreclosure increased FmHA's direct losses from delinquent borrowers.