n7 Evidently, many States take a less Panglossian view than does the majority about the prices paid at sales conducted in accordance with their prescribed procedures. If foreclosure sale prices truly represented what properties are "worth," ante, at 7, or their "fair and proper price," ante, at 14, it would stand to reason that deficiency judgments would be awarded simply by calculating the difference between the debt owed and the "value," as established by the sale. Instead, in those jurisdictions permitting creditors to seek deficiency judgments it is quite common to require them to show that the foreclosure price roughly approximated the property's (appraised) value. See, e.g., Tex. Prop. Code Ann. @@ 51.003-51.005 (Vernon Supp. 1992); see generally Gelfert v. National City Bank, 313 U.S. 221, 85 L. Ed. 1299, 61 S. Ct. 898 (1941); cf. id., at 233 ("The price which property commands at a forced sale may be hardly even a rough measure of its value").