Mike McCarthy co-authored an article on how mezzanine loans—which typically provide an attractive option for borrowers to finance real estate deals during good economic times—have severely stressed these borrowers due to the recent economic downturn caused by the COVID-19 pandemic, causing some borrowers to default on their loans. This article examines how Article 9 of the UCC provides a process for foreclosing on collateral without resorting to New York courts for help.