Conn. Gen. Stat. » Title 52 — CIVIL ACTIONS · Chapter 923a — Uniform Fraudulent Transfer Act
Connecticut General Statutes

Conn. Gen. Stat. § 52-552d (2026)

Value

✓ current as of May 2026
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(a) Value is given for a transfer or an obligation if, in exchange for the transfer or obligation, property is transferred or an antecedent debt is secured or satisfied, but value does not include an unperformed promise made otherwise than in the ordinary course of the promisor's business to furnish support to the debtor or another person.

(b) For the purposes of subdivision (2) of subsection (a) of section 52-552e and section 52-552f, a person gives a reasonably equivalent value if the person acquires an interest of the debtor 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 security agreement.

(c) A transfer is made for present value if the exchange between the debtor and the transferee is intended by them to be contemporaneous and is in fact substantially contemporaneous.

(P.A. 91-297, S. 4.)

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Notes of Decisions
Cited in 10 cases (1 in the last 5 years), 1999–2024 · leading case: Daly v. Deptula (In Re Carrozzella & Richardson), 286 B.R. 480 (D. Conn. 2002).
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Daly v. Deptula (In Re Carrozzella & Richardson), 286 B.R. 480 (D. Conn. 2002). · cites it 7× “§ 548 (d)(2)(A); see Conn. Gen.Stat. § 52-552d(a). In Unified Commercial Capital, 260 B.”
Chorches v. Fleet Mortg. Corp. (In Re Fitzgerald), 255 B.R. 807 (Bankr. D. Conn. 2000). · cites it 23× “Compare Conn. Gen.Stat. § 52-552d with UFTA § 3. 14 However, the version of Section 52-552d *813 originally presented to the Connecticut legislature was a non-uniform version of UFTA § 3 which provided in relevant part as follows: For the purposes of subdivision (2) of…”
Daly v. Fusco (In Re All-Type Printing Inc.), 274 B.R. 316 (Bankr. D. Conn. 2002). · cites it 2× “Satisfaction of an antecedent debt is explicitly acknowledged by C.G.S. § 52-552d(a) to be “value” for purposes of fraudulent transfer analysis.”
Daly v. Kennedy (In Re Kennedy), 279 B.R. 455 (Bankr. D. Conn. 2002). · cites it 2× “Since satisfaction of an antecedent debt is acknowledged by C.G.S. § 52-552d(a) to be “value” for purposes of fraudulent transfer analysis, the individual satisfactions flowing from the Payments provided “reasonably” equivalent value in exchange for those Payments, to the extent…”
Daly v. Parete (In re Carrozzella & Richardson), 270 B.R. 92 (Bankr. D. Conn. 2001). · cites it 5× “Satisfaction of an antecedent debt is explicitly acknowledged by C.G.S. § 52-552d(a) to be “value” for purposes of UFTA fraudulent transfer analysis.”
Daly v. Richardson (In Re Carrozzella & Richardson), 302 B.R. 415 (Bankr. D. Conn. 2003). · cites it 2× “C.G.S. § 52-552d(a). The Defendant has demonstrated that a debt was created when the Richardsons placed the Mortgage Proceeds with the Firm in exchange for the Firm’s promise to repay the Mortgage Proceeds, plus interest, via regular installment payments to Dime under the Second…”
Daly v. Richardson (In re Richardson), 268 B.R. 331 (Bankr. D. Conn. 2001). · cites it 2× “C.G.S. § 52-552d(a). The Defendant supplied evidence of neither.”
Cockerham v. Westphalen, 225 Conn. App. 484 (Conn. App. Ct. 2024). · cites it 2× “’’ Pursuant to § 52-552d (a), ‘‘[v]alue is given for a transfer or an obligation if, in exchange for the transfer or obligation, property is transferred or an antecedent debt is secured or satis- fied, but value does not include an unperformed prom- ise made otherwise than in…”
Horwitt v. Sarroff (D. Conn. 2020). “The “payment of interest and fees pursuant to the parties’ contracts satisfies an antecedent debt under Section 52-552d(a) and is therefore for value.”
Chem. Bank v. Dana, 234 B.R. 585 (D. Conn. 1999). · cites it 2× “” Conn.Gen.Stat. § 52-552d(a). “Value” 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.”
— Conn. Gen. Stat. § 52-552d(a) — 8 cases
Daly v. Deptula (In Re Carrozzella & Richardson), 286 B.R. 480 (D. Conn. 2002). “§ 548 (d)(2)(A); see Conn. Gen.Stat. § 52-552d(a). In Unified Commercial Capital, 260 B.”
Daly v. Fusco (In Re All-Type Printing Inc.), 274 B.R. 316 (Bankr. D. Conn. 2002). “Satisfaction of an antecedent debt is explicitly acknowledged by C.G.S. § 52-552d(a) to be “value” for purposes of fraudulent transfer analysis.”
Daly v. Kennedy (In Re Kennedy), 279 B.R. 455 (Bankr. D. Conn. 2002). “Since satisfaction of an antecedent debt is acknowledged by C.G.S. § 52-552d(a) to be “value” for purposes of fraudulent transfer analysis, the individual satisfactions flowing from the Payments provided “reasonably” equivalent value in exchange for those Payments, to the extent…”
Daly v. Parete (In re Carrozzella & Richardson), 270 B.R. 92 (Bankr. D. Conn. 2001). “Satisfaction of an antecedent debt is explicitly acknowledged by C.G.S. § 52-552d(a) to be “value” for purposes of UFTA fraudulent transfer analysis.”
Daly v. Richardson (In Re Carrozzella & Richardson), 302 B.R. 415 (Bankr. D. Conn. 2003). “C.G.S. § 52-552d(a). The Defendant has demonstrated that a debt was created when the Richardsons placed the Mortgage Proceeds with the Firm in exchange for the Firm’s promise to repay the Mortgage Proceeds, plus interest, via regular installment payments to Dime under the Second…”
— Conn. Gen. Stat. § 52-552d(b) — 1 case
Chorches v. Fleet Mortg. Corp. (In Re Fitzgerald), 255 B.R. 807 (Bankr. D. Conn. 2000). “Compare Conn. Gen.Stat. § 52-552d with UFTA § 3. 14 However, the version of Section 52-552d *813 originally presented to the Connecticut legislature was a non-uniform version of UFTA § 3 which provided in relevant part as follows: For the purposes of subdivision (2) of…”
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