Precisely. OR when they set the bottom track in mortar. When it comes to stucco it entirely depends on what the rest of the home is built out of. You can have a stucco finish laid over any other material. First time I had to pull a window from stucco..the entire home was made of block walls so the entire track was set in mortar the entire way around. The ONLY way to get the window out was a masonry wheel on an angle grinder.