A simple foreclosure action would not fall within subsection 183(10) as this type of action does not normally involve a supply of property to a third party to satisfy in whole or in part a debt or obligation owing by a person which is necessary under subsection 183(10). A post foreclosure private sale would not fall within 183(10) either since it would be difficult to say that such a supply was made for the purpose of satisfying in whole or in part a debt or obligation owing by a person. As a result of statute law, upon obtaining an order of foreclosure, the debt may no longer be owing in some jurisdictions. In addition, under the original foreclosure action, the mortgagee took the property in satisfaction of the debt and it is difficult to see how a subsequent supply of the property by the creditor was a right exercised under an Act of Parliament or the legislature of a province or any agreement to satisfy the debt or obligation. A simple foreclosure action may, however, fall within subsection 183(1).
