“While HELOCs are recourse, to get recourse the lender has to pursue a judicial foreclosure. Not something likely to happen in California. Once the trustee sale happen it wipes out everything. So unless the HELOC buys out the first and judicial forecloses on the house.. they have no recourse. From a practical point of view, high LTV HELOCs in a declining market in California are non-recourse.”
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Yes and no. In this instance it sounds like he is considering paying off a non-recourse purchase money 1st with a HELOC. There is CA case law that suggests a no-cash-out re-fi of a non-recourse loan retains the non-recourse characteristic of the original loan. In this instance, the HELOC may be non-recourse. As an aside, if a HELOC is purchase money it is non-recourse.

A post-purchase HELOC (to pay off CC or buy toys) is a recourse loan and the lender does in fact have recourse even if the 1st forecloses. While the HELOC is “wiped-off” the property, the now unsecured debt still exists and can be turned into a judgment and collected.