Foreclosure Defense Process Challenges

Notice of Sale Defects That Can Void Your Foreclosure

California's non-judicial foreclosure process requires strict statutory compliance. A defective Notice of Trustee's Sale can be grounds to postpone or set aside the sale entirely.

CC § 2924f
Notice Requirements
20 Days
Minimum Notice
3 Publications
Required
Recordation
Required

Required Notice of Sale Contents

Under CC § 2924f, a Notice of Trustee's Sale must contain ALL of the following:

Timing Requirements

California law imposes strict timing requirements for the Notice of Sale:

20-Day Minimum Notice

Notice must be given at least 20 days before the sale date. This means posted, mailed, AND published 20 days prior.

3 Newspaper Publications

Must be published once a week for 3 consecutive weeks in a newspaper of general circulation. First publication must be 20+ days before sale.

Recording Required

Notice must be recorded with the county recorder at least 20 days before the sale.

Posting on Property

Notice must be posted in a conspicuous place on the property at least 20 days before sale.

Count Days Carefully

Timing defects are common. Request certified copies of all filings with date stamps. The recording date, posting date, mailing date, and publication dates must ALL be at least 20 days before sale.

Common Notice Defects

I've seen foreclosures challenged successfully based on these defects:

Wrong Beneficiary

Notice names wrong party as beneficiary, or beneficiary assignment wasn't recorded before NOD.

Incorrect Property Address

Typos, wrong unit numbers, or incomplete legal descriptions can invalidate notice.

Missing Phone Number

Trustee contact info must include phone number during business hours.

Wrong Sale Location

Sale held at different location than stated in notice.

Insufficient Publication

Published in wrong newspaper, wrong dates, or fewer than 3 times.

Missing HBOR Disclosures

Required language about contacting HUD-approved counselor not included.

Improper Mailing

Not sent to correct address, or sent regular mail instead of certified.

Amount Discrepancies

Stated amounts don't match actual loan records or include improper fees.

How to Check for Defects

  1. Get certified copies - Request recorded NOD and NOS from county recorder with date stamps
  2. Request proof of mailing - Demand trustee provide affidavit of mailing with certified mail receipts
  3. Find newspaper publications - Contact newspaper to get copies of all three publications with dates
  4. Document posting - Did you see notice posted? When? Take photos if still there
  5. Compare to requirements - Go through checklist above element by element
  6. Check timeline - Map out all dates to verify 20-day requirements

What to Do If You Find Defects

Notice defects alone may not stop a sale without court intervention. Your options:

FAQ

It depends. Courts distinguish between:

  • Void sales - Fundamental defects (like no authority to foreclose) that make the sale a nullity
  • Voidable sales - Technical defects that may be cured or overlooked if no prejudice shown

You generally need to show the defect caused you harm (e.g., you couldn't reinstate because you didn't get proper notice of your rights).

Yes, but it's harder. After sale, you must:

  • File lawsuit to set aside sale
  • Show defect was "material" (not just technical)
  • Generally tender the debt (with exceptions—see Tender Rule)
  • Act quickly—delays hurt your case

Complete failure to mail the notice is a strong defect. Request the trustee's mailing affidavit. If they can't produce proof of mailing (certified mail receipts, process server affidavit), you have grounds to challenge. A "presumption of mailing" can be rebutted with evidence you never received anything.

Yes. Under CC § 2924, the Notice of Default must:

  • Be recorded in the county where property is located
  • Describe the breach and amount to cure
  • Be mailed to borrower within 10 business days of recording
  • Include contact for loss mitigation options

NOD defects can also be grounds to challenge, especially if they affected your ability to cure.

$240/hour

Found Defects in Your Foreclosure Notice?

I review foreclosure documents for defects and file TROs when violations are found. Time is critical—the closer the sale, the more urgent the need for court intervention.

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