A purchaser at a foreclosure sale must perfect its title in the property by recording a trustee’s deed upon sale before serving the occupant(s) with a 3-day notice to quit.  Under CCP 1161a(b)(3), it is not sufficient for the purchaser to record the trustee’s deed after service of the notice to quit but before filing the unlawful detainer action is filed and served.

California Supreme Court (Chin, J.); December 17, 2018; 6 Cal. 5th 474