The mortgagor may be expressly made a tenant of a mortgagee, and an express provision in the mortgage deed that the mortgagor may remain in possession until some certain event may create an interest in the nature of a term of years1. A demise is implied by a covenant that the mortgagor may remain in possession until default, but there is no such implication where the covenant is that the mortgagee may enter after default2.
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