[4] ... the proper test is whether a mortgagee has taken reasonable precautions to obtain the true market value of the property as of the date of the sale. See Oak Orchard Developments Ltd. v. Isenan [1987] O.J. No. 361 (Ont. H.C.) aff'd [1998] O.J. No. 2334 (Ont. C.A.)... .
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