ARTICLE
29 July 2026

Avoiding A California Nonjudicial Residential Foreclosure – § 2924mFinality, Perfection, And Lien Avoidance Under § 522(f)

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Cox, Castle & Nicholson

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Cox Castle is one of the largest full-service law firms specializing in real estate in the United States. Cox Castle takes an interdisciplinary approach to transactional matters and dispute resolution, leveraging our broad range of expertise and our in-depth understanding of our clients' businesses.
California practitioners navigating residential foreclosures should take note of a significant new decision from the Ninth Circuit Bankruptcy Appellate Panel.
United States Insolvency/Bankruptcy/Re-Structuring
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California Civil Code § 2924m now makes a nonjudicial foreclosure sale not “final” until the mandatory bidding window lapses.

In his article, Michael Davis, along with Aaron E. de Leest and the Hon. (ret.) Meredith Jury, discuss the recent Ninth Circuit Bankruptcy Appellate Panel confirmation under the California Civil Code § 2924m.

To read the full article, click here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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