Foreclosure Defense Post-Foreclosure

Deficiency Judgment Defense—Avoid Personal Liability

California has strong anti-deficiency protections. After foreclosure, you may not owe anything—even if the property sold for less than you owed. Here's what you need to know.

CCP § 580b
Purchase Money
CCP § 580d
Non-Judicial
1-4 Units
Owner-Occupied
No Deficiency
In Most Cases

California's Anti-Deficiency Protections

A "deficiency" is the difference between what you owed and what the property sold for. California limits when lenders can pursue you for this balance.

Good News for Most Homeowners

If your loan was purchase money on your residence and foreclosed non-judicially (trustee sale), you're fully protected. The lender cannot come after you personally for any deficiency.

Key Anti-Deficiency Statutes

Are You Protected?

Your protection depends on several factors:

Protected: Purchase Money + Trustee Sale

Loan used to buy 1-4 unit owner-occupied residence, foreclosed via trustee sale. Full protection under 580b AND 580d.

Protected: Any Loan + Trustee Sale

Even refinance or HELOC, if foreclosed non-judicially. 580d protects against deficiency.

Protected: Approved Short Sale

If lender approved the short sale in writing and you have an agreement waiving deficiency. 580e applies.

Vulnerable: Judicial Foreclosure

If lender chose judicial foreclosure (through courts), they can seek deficiency judgment—but must prove fair value.

Vulnerable: Sold Note + Lawsuit

If lender sold the debt to a collector who sues on the promissory note (not foreclosure), anti-deficiency may not apply.

Vulnerable: Investment Property

Non-owner-occupied property may have different rules. 580b protection is more limited.

The 580d Waiver Trap

Some lenders try to get borrowers to waive anti-deficiency protection. Be careful:

Second Mortgages and HELOCs

Junior lienholders wiped out by senior foreclosure may still sue you on the underlying note—this is NOT a deficiency action under 580d. However, 580b purchase money protection may still apply if the junior was also purchase money.

If You're Sued for Deficiency

If a lender or debt collector sues you after foreclosure:

  1. Don't ignore it - Respond within 30 days or face default judgment
  2. Raise anti-deficiency defenses - Assert 580b, 580d, or 580e protection
  3. Challenge fair value - In judicial foreclosure, lender must credit FMV, not sale price
  4. Check statute of limitations - Varies by claim type (usually 4 years for written contract)
  5. Demand validation - If debt collector, use FDCPA rights

Common Defenses

FAQ

Even if you're protected from deficiency, you may receive a 1099-C for canceled debt. This is a tax issue, not a collection issue:

  • Canceled debt is generally taxable income
  • Exception: insolvency at time of cancellation
  • Exception: principal residence exclusion (may still apply)

Consult a tax professional about your specific situation.

Only if:

  • They successfully sue you and get a judgment
  • Anti-deficiency protections don't apply to your situation
  • They then pursue wage garnishment as a collection method

If protected by 580b or 580d, they cannot sue you at all—no lawsuit, no judgment, no garnishment.

This is nuanced:

  • Pure rate/term refinance (no cash out) - may still be purchase money
  • Cash-out refinance - portion that was cash out loses 580b protection
  • But 580d still protects you after non-judicial foreclosure regardless

Bottom line: if foreclosed by trustee sale, you're protected. If judicial foreclosure or debt lawsuit, it gets complicated.

Yes, if properly handled:

  • Chapter 7 can discharge deficiency debt
  • Chapter 13 can include deficiency in repayment plan
  • Timing matters—bankruptcy filed before or after foreclosure affects treatment

If you're worried about deficiency, consult a bankruptcy attorney about whether filing makes sense.

$240/hour

Facing a Deficiency Lawsuit?

I defend against improper deficiency claims and can help you assert your anti-deficiency rights. Don't pay money you don't owe.

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