Legal Question in Real Estate Law in California

There is no statute of limitations on non-judicial foreclosures. In CA a lender can choose either to sue in court for foreclosure, and if the foreclosure sale results in less than the full amount owed they get a judgment for the balance, or they can non-judicially foreclose (technically called a "trustee's sale"), which is much quicker, easier and cheaper, but they waive the right to recover any shortfall. The statute of limitations only applies to the court foreclosure. As long as a loan is not paid and a mortgage is on the property, that mortgage can be foreclosed into eternity.