§ 483.012.Remedy Not Action to For Recovery of Debt

California’s one-action rule generally requires a secured creditor to proceed first against the real property security before pursuing the borrower personally, and pursuing "an action for the recovery of a debt" secured by a mortgage or deed of trust without first foreclosing on the security can trigger consequences under § 726. Section 483.012 carves out attachment relief pursued within a foreclosure action itself from that characterization: using this title’s remedies in a foreclosure action does not count as an action for the recovery of a debt for purposes of § 726(a), and does not amount to a failure to proceed first against the security.

This carve-out is still bounded by the anti-deficiency statutes at §§ 580b and 580d, which independently limit a creditor’s ability to recover a deficiency on certain purchase-money and other protected loans. Section 483.012 clears away one procedural obstacle to using attachment in a foreclosure case; it does not override those separate substantive limits.