A buyer purchasing after a foreclosure sale, can serve a notice to quit to a tenant/former owner before recording the deed, e.g. before title is “perfected”. Citing Code of Civil Procedure § 1161a and U.S. Financial, L.P. v. McLitus (2016) 6 Cal.App.5th Supp. 1, the Court of Appeal affirmed, stating: “Here we reject the occupant’s claim that the notice to quit is premature, and hold that Code of Civil Procedure section 1161a does not require that title be recorded before the notice to quit is served.” (Dr. Leevil, LLC v. Westlake Health Care Center (Cal. App. 2nd Dist., Div. 6, 2017) 9 Cal.App.5th 450.) http://www.courts.ca.gov/opinions/documents/B266931.DOC