Iowa Code » Chapter 614 — LIMITATIONS OF ACTIONS
Iowa Code

Iowa Code § 614.14 (2026)

Real estate interest transferred by trustee

✓ current as of July 2026
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1. If an interest in real estate is held of record by a trustee, a bona fide purchaser acquires all rights in the real estate which the trustee and the beneficiary of the trust had and any rights of persons claiming by, through or under them, free of any adverse claim including but not limited to claims arising under section 561.13 or claims relating to an interest in real estate arising under section 633.238.

2. A bona fide purchaser is a purchaser for value in good faith and without notice of any adverse claim, who has relied on a current, recorded affidavit in substantially the following form delivered to the purchaser: [Individual trustee] Affidavit in re [insert legal description] I, ............................, being first duly sworn and under oath state of my personal knowledge that:\n\nTue Dec 09 21:59:36 2025 Iowa Code 2026, Chapter 614 (37, 0) 7 LIMITATIONS OF ACTIONS, §614.14\n\n [1] I am the trustee under the trust dated ............................, to which the above-described real estate was conveyed to the trustee by ............................, pursuant to an instrument recorded the ............ day of ........................ [month], ................ [year], recorded in the office of the ........................ County Recorder in ........................ [insert recording data]. [2] I am the presently existing trustee under the trust and am authorized to ............................ [describe the transfer to be made by the trustee to the bona fide purchaser], without any limitation or qualification whatsoever. [3] The trust is in existence and I as trustee am authorized to transfer the interests in the real estate as described in paragraph [2], free and clear of any adverse claims. .................................................... [signature of affiant] Sworn to and subscribed before me by .................................... on this ................ day of ........................ [month], ................ [year] .................................................... [Notary Public in and for the State of ........................] \n [Corporate trustee] Affidavit in re [insert legal description] I, ............................, being first duly sworn and under oath state of my personal knowledge that: [1] ............................ is the trustee under the trust dated ........................, to which the above-described real estate was conveyed to the trustee by ........................, pursuant to an instrument recorded the ............ day of ........................ [month], ................ [year], recorded in the office of the ........................ County Recorder in ........................ [insert recording data]. [2] ............................ is the presently existing trustee under the trust and is authorized to ................................ [describe the transfer to be made by the trustee to the bona fide purchaser], without any limitation or qualification whatsoever, and I am ........................ [officer] of the corporate trustee. [3] The trust is in existence and ........................ as trustee is authorized to transfer the interests in the real estate as described in paragraph [2], free and clear of any adverse claims. .................................................... [signature of affiant] Sworn to and subscribed before me by ...................................., on this ................ day of ........................ [month], ................ [year] .................................................... [Notary Public in and for the State of ........................]

3. As used in this section, “adverse claim” includes a claim that a transfer was or would be wrongful, a claim that a particular adverse person is the owner of or has an interest in the real estate, and a claim that would be disclosed by the examination of any document not of record.

4. Unless clearly provided to the contrary by the instrument of transfer to a purchaser, a trustee transferring an interest in real estate warrants to the transferee all of the following:

a. That the trust pursuant to which the transfer is made is duly executed and in existence.

b. That, to the knowledge of the trustee, the person creating the trust was under no disability or infirmity at the time the trust was created.\n\nTue Dec 09 21:59:36 2025 Iowa Code 2026, Chapter 614 (37, 0) §614.14, LIMITATIONS OF ACTIONS 8\n\n c. That the transfer by the trustee to the purchaser is effective and rightful.

d. That the trustee knows of no facts or legal claims which might impair the validity of the trust or the validity of the transfer.

5. a. A person holding an adverse claim arising or existing prior to January 1, 2009, by reason of a transfer of an interest in real estate by a trustee, or a purported trustee, shall not file an action to enforce such claim after December 31, 2010, at law or in equity, in any court to recover or establish any interest in or claim to such real estate, legal or equitable, against the holder of the record title to the real estate.

b. An action based upon an adverse claim arising on or after January 1, 2009, by reason of a transfer of an interest in real estate by a trustee, or a purported trustee, shall not be maintained either at law or in equity, in any court to recover or establish any interest in or claim to such real estate, legal or equitable, against the holder of the record title to the real estate, legal or equitable, more than one year after the date of recording of the instrument from which such claim may arise.

6. An interest in real estate held of record at any time by a trust shall be deemed to be held of record by the trustee of such trust.

7. This section shall not be construed to limit any personal action against the trustee or purported trustee. [S13, §3447; C24, 27, 31, 35, 39, §11021; C46, 50, 54, 58, 62, 66, 71, 73, 75, 77, 79, 81, §614.14] 91 Acts, ch 183, §33; 92 Acts, ch 1014, §1, 2; 92 Acts, ch 1163, §115; 99 Acts, ch 56, §1; 2000 Acts, ch 1058, §65; 2008 Acts, ch 1119, §12, 13, 39; 2009 Acts, ch 52, §1, 14 Referred to in §614.16 \n

Notes of Decisions
Cited in 11 cases (7 in the last 5 years), 1970–2024 · leading case: David A. Vaudt & Jeanie K. Vaudt v. Wells Fargo Bank, N.A. (Iowa 2024).
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David A. Vaudt & Jeanie K. Vaudt v. Wells Fargo Bank, N.A. (Iowa 2024). · cites it 65× “See Iowa Code § 614.14 (5)(b) (precluding claimants from bringing an adverse claim arising “by reason of” a transfer of property held in trust against a good faith purchaser more than one year after the date of the trustee’s deed).”
Heer v. Thola, 613 N.W.2d 658 (Iowa 2000). · cites it 66× “Iowa Code § 614.14 (5)(b). Thola argues any action to challenge his title to the property must have been initiated within one year from the date of the trustee's deed or it would be barred.”
Chicago & North W. Ry. Co. v. City of Osage, 176 N.W.2d 788 (Iowa 1970). “Sections 614.14 through 614.38, Code, are statutes designed to shorten the period of search required to establish title in real estate and give effect and stability to record titles by rendering them marketable and alienable — in substance to improve and render less complicated…”
South Cent. Iowa Landfill Agency v. Elliott J. Corwin, Tassie L. Corwin & All Parties in Possession (Iowa Ct. App. 2024). · cites it 30× “5 See Iowa Code § 614.14 (5)(b). We find Vaudt v.”
Shaffer v. Tewes (N.D. Iowa 2020). · cites it 7× “) (citing IOWA CODE § 614.14(4)). Neither of the Code provisions cited provide a basis for upholding the validity of the lease here.”
Ron Myers v. City of Cedar Falls (Iowa 2024). · cites it 4× “at 50 (quoting Iowa Code § 614.14 (5)(b)). We had previously held that the one-year limitations period applied to such claims in Heer v.”
Ron Myers v. City of Cedar Falls (Iowa 2024). · cites it 4× “at 50 (quoting Iowa Code § 614.14 (5)(b)). We had previously held that the one-year limitations period applied to such claims in Heer v.”
Sundance Land Co., LLC v. Phillip Remmark & Bobbie Remmark (Iowa 2024). · cites it 2× “3d at 51 (discussing that the causal connection required by Iowa Code § 614.14 turned on when the claim arose).”
Sundance Land Co., LLC v. Phillip Remmark & Bobbie Remmark (Iowa 2024). · cites it 2× “3d at 51 (discussing that the causal connection required by Iowa Code § 614.14 turned on when the claim arose).”
West Lakes Props., L.C. v. Greenspon Prop. Mgmt., Inc. (Iowa Ct. App. 2017). “Iowa Code sections 614.14 to 614.38 and their predecessors are marketable title statutes “designed to shorten the period of search required to establish title in real estate and give effect and stability to record titles by rendering them marketable and alienable—in substance to…”
James A. Stogdill, Christopher Determan, Mathew D. Johnson, Alesha Smith & Kirk E. Yentes v. City of Windsor Heights, Iowa, & Mun. Collections of Am., Inc. (Iowa 2023). “§ 614.14(5)(a) (setting forth limitations on actions “in any court” relating to interests in real estate).”
— Iowa Code § 614.14(2) — 1 case
David A. Vaudt & Jeanie K. Vaudt v. Wells Fargo Bank, N.A. (Iowa 2024). “See Iowa Code § 614.14 (5)(b) (precluding claimants from bringing an adverse claim arising “by reason of” a transfer of property held in trust against a good faith purchaser more than one year after the date of the trustee’s deed).”
— Iowa Code § 614.14(3) — 2 cases
Heer v. Thola, 613 N.W.2d 658 (Iowa 2000). “Iowa Code § 614.14 (5)(b). Thola argues any action to challenge his title to the property must have been initiated within one year from the date of the trustee's deed or it would be barred.”
David A. Vaudt & Jeanie K. Vaudt v. Wells Fargo Bank, N.A. (Iowa 2024). “See Iowa Code § 614.14 (5)(b) (precluding claimants from bringing an adverse claim arising “by reason of” a transfer of property held in trust against a good faith purchaser more than one year after the date of the trustee’s deed).”
— Iowa Code § 614.14(4) — 1 case
Shaffer v. Tewes (N.D. Iowa 2020). “) (citing IOWA CODE § 614.14(4)). Neither of the Code provisions cited provide a basis for upholding the validity of the lease here.”
— Iowa Code § 614.14(5) — 3 cases
South Cent. Iowa Landfill Agency v. Elliott J. Corwin, Tassie L. Corwin & All Parties in Possession (Iowa Ct. App. 2024). “5 See Iowa Code § 614.14 (5)(b). We find Vaudt v.”
Heer v. Thola, 613 N.W.2d 658 (Iowa 2000). “Iowa Code § 614.14 (5)(b). Thola argues any action to challenge his title to the property must have been initiated within one year from the date of the trustee's deed or it would be barred.”
David A. Vaudt & Jeanie K. Vaudt v. Wells Fargo Bank, N.A. (Iowa 2024). “See Iowa Code § 614.14 (5)(b) (precluding claimants from bringing an adverse claim arising “by reason of” a transfer of property held in trust against a good faith purchaser more than one year after the date of the trustee’s deed).”
— Iowa Code § 614.14(5)(a) — 1 case
James A. Stogdill, Christopher Determan, Mathew D. Johnson, Alesha Smith & Kirk E. Yentes v. City of Windsor Heights, Iowa, & Mun. Collections of Am., Inc. (Iowa 2023). “§ 614.14(5)(a) (setting forth limitations on actions “in any court” relating to interests in real estate).”
— Iowa Code § 614.14(5)(b) — 5 cases
Heer v. Thola, 613 N.W.2d 658 (Iowa 2000). “Iowa Code § 614.14 (5)(b). Thola argues any action to challenge his title to the property must have been initiated within one year from the date of the trustee's deed or it would be barred.”
David A. Vaudt & Jeanie K. Vaudt v. Wells Fargo Bank, N.A. (Iowa 2024). “See Iowa Code § 614.14 (5)(b) (precluding claimants from bringing an adverse claim arising “by reason of” a transfer of property held in trust against a good faith purchaser more than one year after the date of the trustee’s deed).”
South Cent. Iowa Landfill Agency v. Elliott J. Corwin, Tassie L. Corwin & All Parties in Possession (Iowa Ct. App. 2024). “5 See Iowa Code § 614.14 (5)(b). We find Vaudt v.”
Ron Myers v. City of Cedar Falls (Iowa 2024). “at 50 (quoting Iowa Code § 614.14 (5)(b)). We had previously held that the one-year limitations period applied to such claims in Heer v.”
Ron Myers v. City of Cedar Falls (Iowa 2024). “at 50 (quoting Iowa Code § 614.14 (5)(b)). We had previously held that the one-year limitations period applied to such claims in Heer v.”
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