Home Foreclosures: 9.4.2.2 Postforeclosure Sale Rights of Redemption
Courts had held in cases decided before the 1994 enactment of section 1322(c)(1) that a debtor may cure a default or pay off the balance owed on a mortgage in bankruptcy even after a completed foreclosure auction, when there is a state law unexpired right of redemption.276 Under those precedents, state law postforeclosure redemption rights come into the debtors’ bankruptcy estate.