Are refinances of first mortgages also nonrecourse loans in CA with Wells Fargo?
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No, they are fully recourse loans.
Actually, there is no yes/no answer. It depends on the nature and terms of the refinance, and the surrounding facts and circumstances.
The more the refinance resembles the original purchase money loan, the more likely a court will consider it to be non-recourse. The more the refinance deviates from the original loan, then the more likely a court will consider it to be recourse.
So, a straight dollar for dollar refinance, with the same lender, will probably retain non-recourse status. A significant cash out refinance, with a different lender, is more likely to be ruled a recourse loan.
The state supreme court has never definitively decided the issue. If you’re concerned, consult a property attorney.