In Houts v. First Trust & Savings Bank (1917) 34 Cal.App. 613, title to the family residence was in the name of the husband's business and the wife was a tenant by an unrecorded lease. When a lender sought to foreclose on its loan secured by the property, the wife argued that her occupancy of the house should have put the lender on inquiry notice that she had a prior leasehold interest in the property. (Id. at p. 614.) The Houts court held that the wife's occupancy did not give rise to a duty to inquire because her interest was consistent with record title being in her husband. (Id. at p. 615.)