That is not entirely true pedrocon. Read CA Civil Code 580d. If you refinance, and the lender pursues a non-judicial foreclosure (99.9% of lenders pursue non-judicial foreclosures), then the lender cannot sue you for a deficiency. It is still non-recourse. Of course, if you have two loans on the property, and you refinance them both, and the 2nd becomes a sold-out junior, then he can come after you for a deficiency. In other words, it would be a recouse loan in this situation.