The following excerpt is from In re Richter, Case No. 6:14-bk-10231-SY (Bankr. C.D. Cal. 2015):
11. Further, the owner's right to cure under state law in the form of an equity of redemption also ends when the foreclosure sale occurs, rather than at a later time. See Cal. Civ. Code 2903 (allowing owner to redeem "before his right of redemption is foreclosed"); Stockwell v. Barnum, 7 Cal. App. 413, 418-19 (1908) (concluding that attempted redemption after completion of foreclosure auction but before delivery of trustee's deed was ineffectual). The gavel rule's interpretation of 1322(c)(1) therefore does not cut off any cure rights a debtor may have under California law.
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.