Connecticut General Statutes

Conn. Gen. Stat. § 52-552f (2026)

Transfers fraudulent as to present creditors

✓ current as of May 2026
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(a) A transfer made or obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without receiving a reasonably equivalent value in exchange for the transfer or obligation and the debtor was insolvent at that time or the debtor became insolvent as a result of the transfer or obligation.

(b) A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time and the insider had reasonable cause to believe that the debtor was insolvent.

(P.A. 91-297, S. 6.)

Cited. 239 C. 109.

Cited. 34 CA 216; 46 CA 199.

Notes of Decisions
Cited in 37 cases (7 in the last 5 years), 1994–2026 · leading case: Geriatrics, Inc. v. McGee, 208 A.3d 1197 (Conn. 2019).
Geriatrics, Inc. v. McGee, 208 A.3d 1197 (Conn. 2019). · cites it 18× “13 Liability also can be established on the basis of constructive fraud when a transfer of the debtor's assets occurs after the creditor's claim arose and other circumstances are present, including that the debtor has not received reasonably equivalent value in exchange for the…”
Daly v. Deptula (In Re Carrozzella & Richardson), 286 B.R. 480 (D. Conn. 2002). · cites it 17× “§ 544 (b), sought to recover certain interest payments, which the Debtor made to the Defendants, on the ground that these payments were fraudulent transfers under Conn. Gen.Stat. § 52-552f. The Bankruptcy Judge ruled in favor of the Defendants in each case, holding that the…”
McKay v. Longman, 211 A.3d 20 (Conn. 2019). · cites it 9× “’’ 16 General Statutes § 52-552f provides: ‘‘(a) A transfer made or obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without…”
Breen v. Judge, 4 A.3d 326 (Conn. App. Ct. 2010). · cites it 13× “The plaintiffs, appealing from the judgment in favor of the defendant, claim that the court improperly (1) failed to pierce Patriot’s corporate veil under either the identity rule or the instrumentality rule, (2) required proof of intent to defraud in order to find certain…”
Daly v. Kennedy (In Re Kennedy), 279 B.R. 455 (Bankr. D. Conn. 2002). · cites it 11× “It is axiomatic that funds held in trust by one person for another do not constitute the beneficial property of the former. Rather, legal title to the trust property is held by the former as trustee for the benefit of the latter.”
Featherston v. Katchko & Son Constr. Servs., Inc., 201 Conn. App. 774 (Conn. App. Ct. 2020). · cites it 15× “Count one asserted a fraudulent transfer claim under CUFTA, specifically, General Statutes § 52-552e. Count two also asserted a fraudulent transfer claim under CUFTA, specifically, General Statutes § 52-552f.”
Daly v. Parete (In re Carrozzella & Richardson), 270 B.R. 92 (Bankr. D. Conn. 2001). · cites it 16× “As set forth in more detail hereafter, judgment must enter in favor of the Defendant since the Trustee has failed to adequately establish his entitlement to relief under C.G.S. § 52-552f. II.JURISDICTION The United States District Court for the District of Connecticut has…”
Wendell Corp. Tr. v. Thurston, 680 A.2d 1314 (Conn. 1996). · cites it 4× “Our cases establish the principle that, in real estate mortgage law, “the plaintiff is entitled to pursue its remedy at law on the notes, or to pursue its remedy in equity upon the mortgage, or to pursue both.”
Robinson v. Coughlin, 830 A.2d 1114 (Conn. 2003). · cites it 3× “General Statutes § 52-552f (b) provides: “A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time and the insider had reasonable…”
Certain Underwriters at Lloyd's, London v. Cooperman, 957 A.2d 836 (Conn. 2008). · cites it 2× “) 15 General Statutes § 52-552f (a) provides: “A transfer made or obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without…”
Epperson v. Ent. Express, Inc., 338 F. Supp. 2d 328 (D. Conn. 2004). · cites it 4× “ed unless action is brought: (1) Under subdivision (1) of subsection (a) of section 52-552e, within four years after the transfer was made or the obligation was incurred or, if later, within one year after the transfer or obligation was or could reasonably have been discovered…”
Tyler v. Schnabel, 641 A.2d 388 (Conn. App. Ct. 1994). · cites it 2× “See General Statutes § 52-552f (b). Nonetheless, the trial court stated that the plaintiff would have to prove fraud by clear and convincing evidence.”
— Conn. Gen. Stat. § 52-552f(a) — 18 cases
Daly v. Deptula (In Re Carrozzella & Richardson), 286 B.R. 480 (D. Conn. 2002). “§ 544 (b), sought to recover certain interest payments, which the Debtor made to the Defendants, on the ground that these payments were fraudulent transfers under Conn. Gen.Stat. § 52-552f. The Bankruptcy Judge ruled in favor of the Defendants in each case, holding that the…”
Daly v. Kennedy (In Re Kennedy), 279 B.R. 455 (Bankr. D. Conn. 2002). “It is axiomatic that funds held in trust by one person for another do not constitute the beneficial property of the former. Rather, legal title to the trust property is held by the former as trustee for the benefit of the latter.”
Daly v. Parete (In re Carrozzella & Richardson), 270 B.R. 92 (Bankr. D. Conn. 2001). “As set forth in more detail hereafter, judgment must enter in favor of the Defendant since the Trustee has failed to adequately establish his entitlement to relief under C.G.S. § 52-552f. II.JURISDICTION The United States District Court for the District of Connecticut has…”
Daly v. Fusco (In Re All-Type Printing Inc.), 274 B.R. 316 (Bankr. D. Conn. 2002).
— Conn. Gen. Stat. § 52-552f(b) — 3 cases
Belford v. Cantavero (In Re Bassett), 221 B.R. 49 (Bankr. D. Conn. 1998).
Daly v. Kennedy (In Re Kennedy), 279 B.R. 455 (Bankr. D. Conn. 2002). “It is axiomatic that funds held in trust by one person for another do not constitute the beneficial property of the former. Rather, legal title to the trust property is held by the former as trustee for the benefit of the latter.”
O'Neil v. Jones (In Re Jones), 403 B.R. 228 (Bankr. D. Conn. 2009).
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