Does the full credit bid rule apply to bad faith waste?

Plaintiff misconceives the holding in Cornelison. The full credit bid rule is concerned with damages and proximate causation. It is independent of the antideficiency statute. In Cornelison, the court invoked the rule despite first finding the antideficiency statute did not bar recovery for bad faith waste. According to the court, the full credit bid extinguished the claim not because the antideficiency statute was inapplicable but because the measure of damages for waste is the diminution in value of the security, and the full credit bid set the value at the outstanding indebtedness. Hence, the plaintiff had not been damaged. As explained by the court: " '[T]he purpose of the trustee's sale is to resolve the question of value and the question of potential forfeiture through competitive bidding....' In Smith v. Allen (1968) 68 Cal.2d 93, 95-96 [65 Cal.Rptr. 153, 436 P.2d 65], this court held that a nonjudicial foreclosure sale, if regularly held, finally fixes the value of the property therein sold." (15 Cal.3d at pp. 606-607, 125 Cal.Rptr. 557, 542 P.2d 981.)