All the lien holders must agree to release their lien(s) or the property cannot be sold. One lien holder cannot dictate to another the terms. CW will say, this is all we allow, but the following lien holders can refuse to accept. A lien in second position can destroy a short sale deal. It's not like foreclosure, where following liens are wiped out. I don't really understand your question, because it could not legally be sold if the second did not agree to release their lien.