Iowa Code » Chapter 684 — VOIDABLE TRANSACTIONS
Iowa Code

Iowa Code § 684.7 (2026)

Remedies of creditors

✓ Iowa Code 2026 (laws through the 2025 session)
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1. In an action for relief against a transfer or obligation under this chapter, a creditor, subject to the limitations in section 684.8, may obtain any of the following:

a. Avoidance of the transfer or obligation to the extent necessary to satisfy the creditor’s claim.

b. An attachment or other provisional remedy against the asset transferred or other property of the transferee if available under applicable law.

c. Subject to applicable principles of equity and in accordance with applicable rules of civil procedure, any of the following:

(1) An injunction against further disposition by the debtor or a transferee, or both, of the asset transferred or of other property.

(2) Appointment of a receiver to take charge of the asset transferred or of other property of the transferee.

(3) Any other relief the circumstances may require.\n\nTue Dec 09 21:57:13 2025 Iowa Code 2026, Chapter 684 (32, 0) 5 VOIDABLE TRANSACTIONS, §684.8\n\n 2. If a creditor has obtained a judgment on a claim against the debtor, the creditor, if the court so orders, may levy execution on the asset transferred or its proceeds. 94 Acts, ch 1121, §11; 2016 Acts, ch 1040, §7, 15 Referred to in §684.8 2016 amendment to subsection 1, paragraph b, applies to a transfer made or an obligation incurred, as provided in §684.6, on or after July 1, 2016; 2016 Acts, ch 1040, §15 \n

Notes of Decisions
Cited in 8 cases (2 in the last 5 years), 2007–2023 · leading case: Larry Schaefer & Elaine Schaefer, Husband & Wife v. Raymond Schaefer v. Larry Schaefer & Elaine Schaefer, Husband & Wife, 795 N.W.2d 494 (Iowa 2011).
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Larry Schaefer & Elaine Schaefer, Husband & Wife v. Raymond Schaefer v. Larry Schaefer & Elaine Schaefer, Husband & Wife, 795 N.W.2d 494 (Iowa 2011). · cites it 6× “See Iowa Code § 684.7 (providing creditors with a cause of action and various remedies against the debtor and transferee); § 684.”
Sergeant v. OneWest Bank, FSB (In re Walter), 462 B.R. 698 (Bankr. N.D. Iowa 2011). · cites it 2× “” Iowa Code § 684.7 (1)(a). According to Defendant, the statutory language limits Trustee’s relief to the amount of the IRS claim.”
Eide v. Nat'l City Capital Corp. (In Re RiversideWorld, Inc.), 366 B.R. 34 (Bankr. N.D. Iowa 2007). · cites it 2× “Iowa Code § 684.7 (l)(a). A debtor, under Iowa’s fraudulent transfer statute is presumed to be insolvent if it is “generally not paying [its] debts as they become due.”
In the Matter of the Est. of Francis O. Glaser, Judy E. Bowling, Fiduciary of the Est. of Francis O. Glaser, & State of Iowa ex rel. Dep't of Revenue v. Sherri M. Kindsfather, 959 N.W.2d 379 (Iowa 2021). · cites it 10× “” Iowa Code § 684.7 (1)(a). The administrator of the estate is authorized to bring an action under Iowa Code section 633.”
Zane Algreen v. Timothy Gardner & Gardner Crop Ins., Inc., 919 N.W.2d 768 (Iowa Ct. App. 2018). · cites it 10× “" Iowa Code § 684.7 (1)(c)(3). Under Iowa Code section 668A.”
In re the Est. of Glaser, 949 N.W.2d 435 (Iowa Ct. App. 2020). · cites it 6× “Kindsfather contends that Iowa Code section 684.7 only allows the administrator to seek relief up to “the amount necessary to satisfy” the DOR’s claim.”
Alice M. Shea v. Theresa Lorenz, No. 14-0898 (Iowa Ct. App. July 9, 2015). · cites it 7× “” Iowa Code § 684.7 (2). Under these provisions, we conclude the court was well within its rights to grant Alice the remedy she sought—the establishment of a constructive trust.”
In re Est. of Glaser, 995 N.W.2d 820 (Iowa Ct. App. 2023). · cites it 2× “” She first argues section 684.7(2) gives her a right to redeem.”
Iowa Code § 684.7(1)(a): 1 case
In the Matter of the Est. of Francis O. Glaser, Judy E. Bowling, Fiduciary of the Est. of Francis O. Glaser, & State of Iowa ex rel. Dep't of Revenue v. Sherri M. Kindsfather, 959 N.W.2d 379 (Iowa 2021). “” Iowa Code § 684.7 (1)(a). The administrator of the estate is authorized to bring an action under Iowa Code section 633.”
Iowa Code § 684.7(1)(c)(3): 1 case
Alice M. Shea v. Theresa Lorenz, No. 14-0898 (Iowa Ct. App. July 9, 2015). “” Iowa Code § 684.7 (2). Under these provisions, we conclude the court was well within its rights to grant Alice the remedy she sought—the establishment of a constructive trust.”
Iowa Code § 684.7(2): 2 cases
Zane Algreen v. Timothy Gardner & Gardner Crop Ins., Inc., 919 N.W.2d 768 (Iowa Ct. App. 2018). “" Iowa Code § 684.7 (1)(c)(3). Under Iowa Code section 668A.”
In re Est. of Glaser, 995 N.W.2d 820 (Iowa Ct. App. 2023). “” She first argues section 684.7(2) gives her a right to redeem.”
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