California Bans Deficiency Judgments In Short Sales (Well, At Least For First Liens)

If Governor Schwarzenegger signs SB 931 beforespecified. Existing law prohibits a deficiency
September 30, 2010, it will add section 580e tojudgment in any case in which the real property
the Code of Civil Procedure which will prohibit firstor an estate for years therein has been sold by
mortgage holders from seeking a deficiencythe mortgagee or trustee under power of sale
judgment in any transaction where they havecontained in the mortgage or deed of trust.
provided written consent to a short sale. ThisThis bill would prohibit a deficiency judgment under
would add significant protections to California'sa note secured by a first deed of trust or first
current anti-deficiency laws (e.g. CCP 726, 580dmortgage for a dwelling of not more than 4 units
and 580b) when dealing with short salein any case in which the trustor or mortgagor
transactions.sells the dwelling for less than the remaining
This new law would provide far more relevantamount of the indebtedness due at the time of
protections for borrowers seeking a short salesale with the written consent of the holder of the
than the protections promised by another lawfirst deed of trust or first mortgage. The bill
awaiting the Governor's signature, SB 1178. As Iwould provide that written consent of the holder
stated in a prior post, SB 1178 would expand theof the first deed of trust or first mortgage to
purchase-money protections of CCP 580b to anythat sale shall obligate that holder to accept the
refinancing of the original purchase-money loan butsale proceeds as full payment and to fully
NOT to any amount taken out in cash from suchdischarge the remaining amount of the
refinancing. Additionally, 580e would apply directlyindebtedness on the first deed of trust or first
to short sale transactions. Therefore, the newmortgage.
580e is the saving grace for those borrowersThe bill would specify that those provisions would
seeking a short sale with a cash-out refinancenot limit the ability of the holder of the first deed
loan.of trust or first mortgage to seek damages and
Although this is great news for all of us workinguse existing rights and remedies against the
to help financially troubled homeowners, don'ttrustor or mortgagor or any 3rd party for fraud
break out the Champagne glasses just yet.or waste if the trustor or mortgagor commits
Serious questions remain about how this new laweither fraud with respect to the sale of, or waste
will be implemented and interpreted. For instance,with respect to, the real property that secures
can the borrower waive the protections affordedthat deed of trust or mortgage. The bill would
by 580e? What happens if the lender keeps themake these provisions inapplicable if the trustor or
language in the approval letter reserving the rightmortgagor is a corporation or political subdivision
to seek a deficiency? Is that considered a waiverof the state.
of 580e? What if the lender asks for, and theThe new section 580e would read as follows:
borrower signs, a new promissory note? These580e.
issues will not be resolved any time soon.(a) No judgment shall be rendered for any
Therefore, real estate agents and lawyers alikedeficiency under a note secured by a first deed
should be very cautious in giving advice about theof trust or first mortgage for a dwelling of not
implication of both the new 580e and the revisedmore than four units, in any case in which the
580b (if the bills are signed into law). What we cantrustor or mortgagor sells the dwelling for less
do is use the new law as significant leveragethan the remaining amount of the indebtedness
against the first lien holder to force the completedue at the time of sale with the written consent
REMOVAL of the deficiency language from theof the holder of the first deed of trust or first
approval letters.mortgage. Written consent of the holder of the
What the legislature has yet to address is thefirst deed of trust or first mortgage to that sale
second lien issue. These laws have no effect onshall obligate that holder to accept the sale
second lien holders (lenders and other creditorsproceeds as full payment and to fully discharge
alike). As we all know, the second lien holder canthe remaining amount of the indebtedness on the
be far more troublesome than the first... this newfirst deed of trust or first mortgage.
law will not affect them in any way. As all lenders(b) If the trustor or mortgagor commits either
become more and more aggressive, we will needfraud with respect to the sale of, or waste with
some leverage against the second lien holders.respect to, the real property that secures the
Until then, we will need to keep fighting backfirst deed of trust or first mortgage, this section
against their unreasonable demands.shall not limit the ability of the holder of the first
The LEGISLATIVE COUNSEL'S DIGEST for thedeed of trust or first mortgage to seek damages
new law reads as follows:and use existing rights and remedies against the
Existing law authorizes an action for a deficiencytrustor or mortgagor or any third party for fraud
judgment for the balance due upon an obligationor waste.
for the payment of which a deed of trust or(c) This section shall not apply if the trustor or
mortgage with power of sale upon real propertymortgagor is a corporation or political subdivision
or any interest therein was given as security, asof the state.