But, you say, in California there are no deficiencies permitted following non-judicial foreclosure and thus section 580a is meaningless. Well, not entirely. 580a was adopted before 580d; thus, at one time, a deficiency, subject to the fair value limitations of 580a, was permitted. Even after adoption of 580d, a junior sold out by a senior non-judicial foreclosure sale is entitled to a deficiency. See Commentary.Deficiency after non-judicial foreclosure. If the sold out junior is the high bidder at the senior non-judicial foreclosure sale, the fair value limitations of 580a will limit the amount of deficiency it can recover.