RULE re. possession before foreclosure: lien theory state vs. title state vs. intermediate title state:
lien theory: Mortgagee/lender cannot take possession prior to foreclosure because lender has a lien until foreclosure is complete. Mortgagor is owner up until foreclosure.
title theory: lender technically has the right, as the holder of title, to possess property at any time
intermediate title: (minority of jurisdictions) the mortgagor retains title until default, at which point lender can take possession