California has had an interesting exercise in this very issue and it is not as cut and dry as either side might think.  Here are a few nuances:

  Some HOA's claim that their lien is superior because the establishing CC&R's are typically recorded upon building of a subdivision and precede (on record) the later mortgage lien by a new home buyer.  The new home buyer has been given notice in his title policy that the HOA Declaration does exist and contains monthly dues, hence it constitutes a prior lien over the mortgage.  There is at least once case pending in our courts that seems to be reviewing the matter as having some substance. 

  ALSO AND MORE IMPORTANTLY, if the HOA Lien or HOA default notice recorded prior to the mortage (deed of trust) document, then it certainly has priority (obviously, unless subordinated to), and is NOT wiped out in foreclosure.

  Hate to say it, but another Robert (this time Alvey) might be right.  LOL! 

  Sorry to both Roberts...I alway manage to jab at ya from outside the box.