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Fraudulent Transfers in Washington StateTransfers without adequate consideration or gifts can be overturned as fraudulent in certain circumstances. This article discusses breaking asset protection trusts and other devices to avoid creditors Briefly transferring house to wife to obtain loan is fraudulent transfer Attacking Trusts and Other Asset Protection Schemes in which the Settlor is NOT a Beneficiary Fraudulent Transfer in WashingtonStatute of Limitations for fraudulent transfers Establishing actual fraudulent intent Constructive frauds in general What is reasonably equivalent value (REV)? 1. Transfers without REV and debtor insolvent 2. Transfers without REV, remaining assets unreasonably small 3.Transfers made without REV, debtor unable to pay remaining debts
The Internet is replete with websites touting asset protection schemes. What they do not reveal is that they are unlikely to work. Most states have statutes that protect creditors from asset protection schemes through a variety of tools. Unless the trust does not benefit the debtor, it is unlikely to serve its purpose. This article discusses the various applicable statutes in Washington State. An asset protection trust is an entity created by and recognized by court-made law (common law). “Asset protection” is a label applied to a common law trust specifying its purpose but not describing a unique entity. Some trusts, like Massachusetts Business Trusts, are entities chartered by Washington’s Secretary of State in a process similar to the creation of a corporation or limited liability company. Asset protection trusts generally rely on the non-chartered and therefore more secret trusts created under common law. Modern trust law is primarily the product of centuries of decisions starting from the 13th century in the courts of equity (Court of the Chancery) of England. Trusts are now internationally recognized by the Hague Convention on the Law Applicable to Trusts and on their Recognition effective January 1, 1992. An intentionally established trust (“express” trust) involves at least three persons: 1) the settlor(s) or trustor(s) who transfers property in trust to the trustee; 2) the trustee(s) who owns legal title to the property in her own name or in the name of the trust for the benefit of the beneficiary; and 3) the beneficiary who receives money or property from the trust according to its terms. In fraud cases, the self-settled trust is usually the easiest trust to attack. A self-settled trust is a trust in which the settlor is one of the beneficiaries. Washington law makes self-settled trusts ineffective against existing or subsequent creditors of the settlor. RCW 19.36.020 provides: . . . all deeds of gift, all conveyances, and all transfers or assignments, verbal or written, of goods, chattels or things in action, made in trust for the use of the person making the same, shall be void as against the existing or subsequent creditors of such person. There is no requirement of intent to defraud or a time limit in this statute. Even if the settlor transfers assets to a self-settled trust in good faith and twenty years passes, creditors can theoretically attach the assets. Washington courts have not considered whether to limit the statute’s endless reach but have hinted that equitable defenses like laches (inequitable delay) apply (See Prater v. Houston, 123 Wash. 640, 212 P. 1064 (1923)). Federal bankruptcy law has additional provisions regulating self-settled trusts that overlap Washington law. Either bankruptcy law or state law can be used to attack a self-settled trust (In re Wallaert, 149 B.R. 665 (Bkrtcy.W.D.Wash.1992). The Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 added a new section 548(e), addressing self-settled trusts, changing former by extending the reach-back to the assets of self-settled trusts from one year to ten years. The trustee's independent powers under section 548 to avoid fraudulent transfers now allows avoidance of any transfer by the debtor within 10 years before the filing of the petition, to a self-settled trust or "similar device", if the debtor is a beneficiary of the trust or device and the transfer was made with "actual intent to hinder, delay, or defraud any entity to which the debtor was or became, on or after the date that such transfer was made, indebted." In order to show the requisite fraudulent intent under section 548(e), the trustee must relate the debtor's intent to actual (contemporaneous or subsequent) creditors, rather than merely showing that the debtor created the device and transferred an asset to it. This "actual intent" language is substantially identical to the language used in the Uniform Fraudulent Transfers Act (UFTA) enacted in Washington as RCW 19.40.011. Because no intent is required to use RCW 19.36.020 to allow attachment by past, present, and future creditors, the bankruptcy provisions are rarely needed in Washington State to reach the assets of self-settled trusts. Attacking Trusts and Other Asset Protection Schemes in which the Settlor is NOT a Beneficiary If the settlor is not a beneficiary, reaching the assets of the trust is far more difficult. The primary means of attack is as a fraudulent transfer or perhaps a preference in bankruptcy court. Fraudulent Transfer in Washington Washington adopted the Uniform Fraudulent Transfer Act (UFTA) in 1988 to replace the Uniform Fraudulent Conveyance Act (UFCA) of 1945. The UFCA was the first Washington statute to replace the common law developed under the Statute 13 Elizabeth (1570). Under UFTA, there is no requirement that a creditor first obtain a judgment to reach property fraudulently transferred by a debtor. A creditor without a judgment may attach or garnish the property, may enjoin its further transfer, or may have a receiver appointed to control the property. Since prejudgment remedies usually requires the posting of a sizeable bond and is not final until the fraudulent transfer is proven, the creditor often chooses to establish the fraudulent character of a transfer in court first. A “transfer” includes every mode, direct or indirect, absolute or conditional, voluntary or involuntary, of disposing of or parting with an asset or an interest in an asset, and includes payment of money, release, lease, and creation of a lien or other encumbrances (RCW 19.40.011(12)). Exempt and fully encumbered properties are not considered to be “assets” (RCW 19.40.011(2)) “Transfer” includes involuntary transfers such as transfers of interests in foreclosures, other security realization proceedings, and lease terminations based on the debtor's default. However, in general, noncollusive foreclosure proceedings are not voidable. UFTA also provides that transfers of interests in connection with creditors' realization under security agreements in compliance with UCC Article 9 and with termination of leases under lease default provisions are not voidable (RCW 19.40.081(f)). Statute of Limitations for fraudulent transfers UFTA has three statute of limitations, each of which bars the claim, not just the remedy: 1) a four-year limit for constructively fraudulent transfers based on lack of reasonably equivalent value having been given; 2) a one-year limit for insider preferential transfers; 3) and a discovery rule as an alternative to the four-year limit for transfers made with actual fraudulent intent. Under the UFTA statute of limitations, this cause of action is extinguished four years after the transfer was made or the obligation was incurred or, if later, one year after the transfer or obligation was or could reasonably have been discovered by the claimant (RCW 19.40.091(a)). Washington holds the UFTA continues the common law and the UFCA rule that a claimant must have knowledge of the fraudulent nature of a transfer before the statute of limitations begins to run. Freitag v. McGhie, 133 Wash. 2d 816, 947 P.2d 1186 (1997), as amended, (Dec. 18, 1997) (5-4 decision), overruling McMaster v. Farmer, 76 Wash. App. 464, 886 P.2d 240 (Div. 1 1994). Therefore an action may be commenced (under the discovery rule) any time within one year of the discovery of the fraudulent nature of the transfer rather than within one year of the discovery of the transfer. The statute of limitations period starts to run when the transfer of an “asset” is made. An “asset” is property owned by the debtor in which the debtor has equity. Fully encumbered property is therefore not an asset (RCW 19.40.011(2)(i)). Property exempt under either state or federal nonbankruptcy law is also not an asset (RCW 19.40.011(2)(ii)). A transfer is made when the transfer is perfected under the relevant law. A transfer of real property other than a fixture occurs when the transfer is perfected so that a good faith purchaser cannot acquire an interest in the asset from the debtor that is superior to the interest of the transferee (RCW 19.40.061(1)(i)). A transfer of an asset that is not real property or that is a fixture is made when it is so far perfected that a creditor on a simple contract cannot acquire a judicial lien superior to the interest of the transferee (RCW 19.40.061(1)(ii)). If the transfer is not perfected before commencement a UFTA action, the transfer is deemed made immediately before the commencement of the action (RCW 19.40.061(2)). If applicable law does not permit perfection of a transfer, the transfer is made when it becomes effective between the debtor and the transferee (RCW 19.40.061(3)). Under UFTA fraudulent transfers are made voidable, not void. Therefore, if a transfer is complete, title will have passed to the transferee and perhaps to a subsequent transferee or transferees. Those parties will be entitled to notice and an opportunity to be heard on any seizure of the property as well as on avoidance questions. A good-faith transferee will be protected to the extent of value given. Protection may be afforded by: a lien on the asset or retention of any interest received, enforcement of any obligation incurred, or a reduction in the amount of the liability on the judgment (RCW 19.40.081(e)). UFTA also provides that the principles of law and equity supplement it unless displaced by the provisions of UFTA. It includes as supplemental possibilities the law merchant and the law relating to principal and agent, estoppel, laches, fraud, misrepresentation, duress, coercion, mistake, insolvency, or other validating or invalidating cause (RCW 19.40.902). Creditors have three avenues of recovery under the UFTA. They may recover by selling the fraudulently transferred property, by obtaining a judgment against the transferor, and by obtaining a judgment against the transferee. All three remedies may be pursued at the same time but naturally the total recovery is limited to total damages suffered by the creditor. To recover from the transferee, creditor must prove the debtor's actual intent to hinder, delay, or defraud. A creditor with a cause of action for any type of fraudulent conveyance may: (1) Have the transfer or obligation avoided to the extent necessary to satisfy the creditor's claim; (2) Attach the asset transferred or other property of the transferee or use garnishment when appropriate; (3) Obtain an injunction against further disposition by the debtor or transferee (or both) of the asset transferred or of other property; (4) Obtain appointment of a receiver to take charges of the asset transferred or of other property of the transferee; or (5) Seek any other relief that the circumstances may require. The injunction remedy and appointment of a receiver require the posting of bond which could be for significant sums. Bonds are difficult for smaller creditors to obtain and so they must follow the alternative procedure of depositing cash into the registry of the court in lieu of bond. This requirement often makes these equitable remedies unavailable to small business and creditors who are not wealthy. The amount of the creditor’s judgment against the asset will be based on the value of the asset at the time of transfer, subject to adjustment for fairness. Equities requiring adjustment of the value include enhancement of value of the property as the result of improvements made by a good faith transferee (requiring reimbursement for the transferee) or diminution of value by severance of timber or enrichment of the transferee by net income from the property such as rents collected. If the value is diminished, the transferee's liability increases. The UFCA (the former statute) did not specifically grant a defrauded creditor the right to hold a transferee personally liable for the value of assets transferred, but the Washington Court of Appeals had held that that remedy was available if the transferee “knowingly accepted the property with an intent to assist the debtor in evading the creditor and … placed the property beyond the creditor's reach”. (Deyong Management, Ltd. v. Previs, 47 Wash. App. 341, 347, 735 P.2d 79, 83 (Div. 1 1987). The UFTA (which replaced the UFCA) imposes liability on the transferee if 1) the transfer was made with actual fraudulent intent; 2) if the transferee did not act in good faith; and 3) the transferee did not give reasonably equivalent value. Thus, a transferee who acted in good faith, with no intent to assist the debtor to evade creditors, is still personally liable if reasonably equivalent value was not given. Despite this change in the UFTA, Division 3 of the Washington Court of Appeals (Spokane), relying on a decision under the UFCA, affirmed dismissal of a creditor's action against good faith transferees even though they had given no consideration ([Thompson v. Hanson 239 P.3d 537 (Wash.,2010) transferees were liable even absent showing of intent to hinder or delay any creditor, overruling Park Hill Corp. v. Don Sharp, Inc., Better Homes and Gardens, 60 Wash. App. 283, 803 P.2d 326 (Div. 3 1991), relying on Deyong Management, Ltd. v. Previs, 47 Wash. App. 341, 347, 735 P.2d 79, 83 (Div. 1 1987). Division 2 has rejected Division 3's limitations on recovery from an initial transferee, concluding that the plain language of the UFTA permits entry of judgment against the first transferee or the person for whose benefit the transfer was made. A transfer made or an obligation incurred by a debtor with actual intent to hinder, delay, or defraud any creditor of the debtor is fraudulent as to both present and future creditors. There is a defense for good faith transferees. If a person took the asset in good faith and for a reasonably equivalent value, the transfer is not voidable. Value means something of real value to the creditor. The 1985 comment to the UFTA states that: ““[v]alue” is to be determined in light of the purpose of the act to protect a debtor's estate from being depleted to the prejudice of the debtor's unsecured creditors. Consideration having no utility from a creditor's viewpoint does not satisfy the statutory definition.” (Uniform Fraudulent Transfer Act, § 3 comment, 7A U.L.A. 650 (1984) quoted with approval in Clearwater v. Skyline Const. Co., Inc. 67 Wash.App. 305, 322-323, 835 P.2d 257, 267 (Wash.App. Div. 1, 1992) If the transaction is between spouses, good faith must be proven by the transferor (RCW 26.16.210). If a transfer is voidable, a creditor may obtain a judgment against the transferee instead of, or as well as, seeking to avoid the transfer or obligation. Establishing actual fraudulent intent The Act lists eleven non-exclusive factors, similar to common law “badges of fraud”, for determining whether the debtor had actual intent to hinder, delay, or defraud creditors (Clayton v. Wilson, 168 Wash.2d 57, 70, 227 P.3d 278, 284 (2010; RCW 19.40.041). All the factors tend to establish actual fraudulent intent except numbers eight and three: 1.The transfer or obligation was to an insider; 2. The debtor retained possession or control of the property transferred after the transfer; 3. The transfer or obligation was disclosed or concealed; 4. Before the transfer was made or obligation was incurred, the debtor had been sued or threatened with suit; 5. The transfer was of substantially all the debtor's assets; 6. The debtor absconded; 7. The debtor removed or concealed assets; 8. The value of the consideration received by the debtor was not reasonably equivalent to the value of the asset transferred or the amount of the obligation incurred; 9. The debtor was insolvent or became insolvent shortly after the transfer was made or the obligation was incurred; 10. The transfer occurred shortly before or shortly after a substantial debt was incurred; and 11. The debtor transferred the essential assets of the business to a lienor who transferred the assets to an insider of the debtor. Even if circumstantial evidence of fraud can be established through the eleven statutory elements, there will likely be a trial on the issue of intent. The transferor will deny intent to defraud so the trier of fact must hear testimony and assess the witnesses' credibility on the issue of good faith. Proof of actual intent to defraud must be demonstrated by clear and convincing evidence, while only substantial evidence is necessary to establish the other types of fraud (see Sparkman & McLean Co. v. Derber, 4 Wash.App. 341, 481 P.2d 585 (1971); N.B. legal experts suggest this case does not fully consider all the possible burdens of proof). Summary judgment may be possible (1) if the transfer was to a spouse or domestic partner (RCW 26.16.210 – burden to prove good faith shifts to transferor) or other insider and (2) the transferor becomes insolvent because of the transfer (“the act of transferring the property is conclusive evidence of fraud, and the intent is presumed from the act” since it rendered the transferor insolvent, Clayton v. Wilson, 168 Wash.2d 57, 71, 227 P.3d 278, 284 (Wash., 2010). However summary judgment can be avoided if insolvency is denied and cannot be easily proven). In Clayton the court reached its result by looking to the Act’s mention of “insiders” which the court defined as “a broad group that includes relatives, as well as partnerships, general partners, and corporations”.) Constructive frauds in general A constructively fraudulent transfer or obligation is fraudulent regardless of the transferor or transferee’s intent. Under RCW 19.40.041, a creditor must establish that the transfer was made to an insider or that the transferor did not receive reasonably equivalent value in exchange and: (1) The debtor was insolvent at the time of the transfer or became insolvent as a result of the transfer or obligation (fraudulent only as to present creditors) RCW 19.40.041(b)(9)]; or (2) The debtor was engaged in or about to engage in a business or a transaction for which the debtor's remaining assets were unreasonably small in relation to the business or transaction (fraudulent as to both present and future creditors),[RCW 19.40.041(a)(2)(i)]; or (3) The debtor intended to incur, or believed or reasonably should have believed that he or she would incur, debts beyond his or her ability to pay as they became due (fraudulent as to both present and future creditors).[ RCW 19.40.041(a)(2)(i)]. What is “reasonably equivalent value” (REV)? “Reasonably equivalent value” is not defined in the Act except in the context of foreclosure. The REV concept is adopted from the fraudulent transfer provision of the Bankruptcy Code [11 U.S.C.A. § 548(a)(2)] so decisions under the Code provide guidance to its meaning. The Act defines “Value” as property transferred or antecedent debt is secured or satisfied in exchange for a transfer or obligation, but it excludes an executory promise to furnish support to the debtor or another person unless the promise is made in the ordinary course of the promisor's business [RCW 19.40.031(a)]. In the case of a grant of a security interest, reasonably equivalent value is the value of the interest transferred and the value exceeding the debt is available to creditors [Sedwick v. Gwinn, 73 Wash. App. 879, 873 P.2d 528 (Div. 1 1994)]. A transfer is for “present value” if the exchange is intended by the debtor to be contemporaneous and is in fact substantially contemporaneous [RCW 19.40.031(c)]. The price paid for property at a foreclosure sale is often substantially below fair market value. The UFTA provides a safe harbor for purchasers who give “reasonably equivalent value” if the purchaser acquires a debtor's interest in an asset pursuant to a regularly conducted, noncollusive foreclosure sale or execution of a power of sale for the acquisition or disposition of the interest of the debtor upon default under a mortgage, deed of trust, or UCC Article 9 security agreement [RCW 19.40.031(b)]. In 5-41 decision, the United States Supreme Court reached the same conclusion regarding mortgage foreclosure sale of real estate [BFP v. Resolution Trust Corp., 511 U.S. 531, 114 S. Ct. 1757, 128 L. Ed. 2d 556 (1994)]. A transfer is not voidable if a secured party enforces a security interest in compliance with UCC Article 9 or if a landlord terminates a lease after default pursuant to the lease and applicable law [RCW 19.40.081(e)]. UFTA sanctions three types of transfers even if the transferee is innocent of actual fraud. This is known as constructive fraud and arises when the transferor after the transfer 1) is insolvent; 2) is left with an unreasonably small amount of capital to carry on business; or 3) does not have enough assets to pay creditors. 1. Transfers without REV and debtor insolvent The law deems a transfer or obligation to be constructively fraudulent (regardless of the knowledge or intent of the transferee) if 1) the transferor did not receive reasonably equivalent value in exchange and 2) the transferor was insolvent at the time of the transfer or became insolvent as a result of the transfer or obligation [RCW 19.40.051(a)]. There are two tests of insolvency. Proof of either one is sufficient to prove insolvency. A debtor is insolvent under the “asset test” if the sum of the debtor's debts is greater than the fair valuation of the debtor's assets [RCW 19.40.021(a)]. A debtor who is not paying his or her debts as they become due is presumed to be insolvent [RCW 19.40.021(b)] under the “debt payment test”. Transferred property reduces the assets of the debtor and increases the likelihood of insolvency under the asset test. In other words, “assets” as used in the definition of insolvency do not include property that has been transferred, concealed, or removed with intent to hinder, delay, or defraud creditors or that has been transferred in a manner making the transfer voidable under the UFTA [RCW 19.40.021(d)]. Under the debt repayment test, “debts” used in the calculation of insolvency do not include an obligation secured by a “valid” lien on property of the debtor not included as an asset (e.g. exempt or transferred property) to the extent of the value of the asset. The amount of the debt that exceeds the value of the collateral is “debt” [RCW 19.40.021(d)]. A lien is “valid” if it is effective against the holder of a judicial lien subsequently obtained by legal or equitable process or proceedings [RCW 19.40.011(13)]. Constructively fraudulent transactions due to insolvency are only fraudulent to creditors whose claims arose before the transfer was made or the obligation was incurred [RCW 19.40.051(a)]. The statute of limitations for this type of constructive fraud actions is four years after the transfer was made or the obligation was incurred [RCW 19.40.091(b)]. 2. Transfers without REV, remaining assets unreasonably small The law deems a transfer or obligation to be constructively fraudulent (regardless of the knowledge or intent of the transferee) if 1) the transferor did not receive reasonably equivalent value and the debtor was engaged in or about to engage in a business or a transaction for which the debtor's remaining assets were unreasonably small in relation to the business or transaction [RCW 19.40.041(a)(2)(i)]. This type of constructive fraud is fraudulent as to both present and future creditors [RCW 19.40.041(a)]. The statute of limitations for this type of constructive fraud actions is four years after the transfer was made or the obligation was incurred [RCW 19.40.091(b)]. 3.Transfers made without REV, debtor unable to pay remaining debts A transfer or obligation is constructively fraudulent if it is made or incurred without the debtor receiving reasonably equivalent value and the debtor intended to incur, or believed or reasonably should have believed that he or she would incur, debts beyond his or her ability to pay as they became due [RCW 19.40.041(a)(2)(ii)]. The Washington Court of Appeals applied this rule to a construction contract case. The contractor was a corporation which purchased land to build a custom house under a contract with the buyer of the house. A dispute over construction costs developed. Nine months after the purchase and just before litigation began, the president of the construction company transferred the property to herself without consideration. She claimed the original deed in the corporation’s name was a mistake. The trial court accepted this testimony and did not find a fraudulent transfer even though it found several “badges of fraud”. The appellate court agreed that there was no proof of fraudulent intent but concluded there was constructive fraud because there was not REV and the contractor corporation was left without sufficient funds to pay the judgment. Clearwater v. Skyline Const. Co., Inc., 67 Wash.App. 305, 321, 835 P.2d 257, 266 (Wash.App. Div. 1,1992). This case also left in place the two tier burden of proof: “. . . [U]nder the Uniform Fraudulent Conveyance Act (UFCA), which preceded the UFTA and which contained essentially similar provisions, proof of actual intent to defraud was to be demonstrated by “clear and satisfactory proof”. In contrast, proof of a fraudulent conveyance on the other statutory grounds was to be shown by “substantial evidence”. . . . . [W]e adopt the foregoing distinction between the quantum of evidence required to prove actual intent to defraud and that required to prove a fraudulent transfer on the other grounds provided under the UFTA”. Thus only “substantial evidence” was required to prove fraudulent transfer when the debtor is unable to pay remaining debts. This type of transaction is fraudulent as to both present and future creditors [RCW 19.40.041(a)]. Under the UFTA statute of limitations, this cause of action must be brought within four years after the transfer was made or the obligation was incurred [RCW 19.40.091(b)]. A transfer to an insider for an antecedent debt is deemed fraudulent if the debtor was insolvent at the time and the insider had reasonable cause to believe that the debtor was insolvent. The definition of insolvency is the same throughout UFTA. See previous section. Preferences are only fraudulent to creditors whose claims existed at the time of the transfer [RCW 19.40.051(b)]. Under the UFTA statute of limitations, this cause of action must be brought within one year after the transfer was made or the obligation was incurred [RCW 19.40.091(c)]. The “insider” term is defined in detail in the UFTA and is based on the bankruptcy code definition [11 U.S.C. § 101(31)]: (7) “Insider” includes: (i) If the debtor is an individual: (A) A relative of the debtor or of a general partner of the debtor; (B) A partnership in which the debtor is a general partner; (C) A general partner in a partnership described in subsection (7)(i)(B) of this section; or (D) A corporation of which the debtor is a director, officer, or person in control; (ii) If the debtor is a corporation: (A) A director of the debtor; (B) An officer of the debtor; (C) A person in control of the debtor; (D) A partnership in which the debtor is a general partner; (E) A general partner in a partnership described in subsection (7)(ii)(D) of this section; or (F) A relative of a general partner, director, officer, or person in control of the debtor; (iii) If the debtor is a partnership: (A) A general partner in the debtor; (B) A relative of a general partner in, or a general partner of, or a person in control of the debtor; (C) Another partnership in which the debtor is a general partner; (D) A general partner in a partnership described in subsection (7)(iii)(C) of this section; or (E) A person in control of the debtor; (iv) An affiliate, or an insider of an affiliate as if the affiliate were the debtor; and (v) A managing agent of the debtor [RCW 19.40.011]. This list is not exclusive. There may be other situations that the court will find an “insider” relationship exists. A “relative” includes an individual related by consanguinity within the third degree as determined by the common law, a spouse, or an individual related to a spouse within the third degree as so determined, and includes an individual in an adoptive relationship within the third degree [RCW 19.40.011(11)]. Defenses to insider preference claims A transfer to an insider is not voidable in three circumstances [RCW 19.40.081(f)]:(1) To the extent the insider gave new value, not secured by a valid lien, to or for the benefit of the debtor after the transfer was made; (2) If made in the ordinary course of business or financial affairs of the debtor and the insider; or (3) If made pursuant to a good-faith effort to rehabilitate the debtor, and the transfer secured present value given for that purpose as well as an antecedent debt of the debtor. A lien is valid if it is effective against the holder of a judicial lien subsequently obtained by legal or equitable process or proceedings [RCW 19.40.011(13)]. Court decisions on the parallel bankruptcy provisions give guidance in application of these UFTA defenses. |
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