Legal Question in Real Estate Law in California

It depends on what type of tax lien and when notice of the lien was recorded, relative to the lender's first deed of trust. Almost all tax liens are subordinate to properly recorded and perfected deeds of trust and other liens that appear in the public record before the notice of the tax liens. Therefore the lender doesn't need any recourse, really. If the IRS or FTB forecloses on their junior lien, they take the property subject to the lender's lien. So unless the taxing authority is seeking to assert a lien that has priority regardless of when it was recorded, or is claiming the lender's lien is junior to the tax lien, the lender remains secured.