Is there only one action for recovery of a debt secured by a trust deed?

It is declared in Brown v. Jensen, 41 Cal.2d 193, 259 P.2d 425, that under section 726, Code of Civil Procedure, there can be but one action for the recovery of a debt secured by a trust deed, namely, one of foreclosure. Certain exceptions to the above principle are then mentioned, including situations where the security has been rendered valueless through no fault of the beneficiary under the trust deed; an action on the note will then lie because the events which caused the security to become valueless were not contemplated at the time the money was loaned and the trust deed given. Section 580b, as the court then noted, covers a special type of security transaction, to wit, a purchase money trust deed; a party taking such a trust deed knows the value of his security and assumes the risk that it may become

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