Iowa Code

Iowa Code § 684.9 (2026)

Extinguishment of claim for relief

✓ current as of July 2026
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A claim for relief with respect to a transfer or obligation under this chapter is extinguished unless action is brought as follows:

1. Under section 684.4, subsection 1, paragraph “a”, not later than four years after the transfer was made or the obligation was incurred or, if later, not later than one year after the transfer or obligation was or could reasonably have been discovered by the claimant.

2. Under section 684.4, subsection 1, paragraph “b”, or section 684.5, subsection 1, not later than four years after the transfer was made or the obligation was incurred.

3. Under section 684.5, subsection 2, not later than one year after the transfer was made. 94 Acts, ch 1121, §13; 2016 Acts, ch 1040, §9, 15 2016 amendment 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 7 cases, 2005–2020 · leading case: United States v. Equip. Acquisition Resource, 742 F.3d 743 (7th Cir. 2014).
United States v. Equip. Acquisition Resource, 742 F.3d 743 (7th Cir. 2014). “These include Iowa, Iowa Code Ann. § 684.9 (five years); Kentucky, Ky.”
In Re Schaefer, 331 B.R. 401 (Bankr. D. Iowa 2005). · cites it 2× “Iowa Code § 684.9 ; see also 684.7 (remedies of creditors).”
Sergeant v. G.R.D. Investments L.L.C. (Schaefer), 331 B.R. 401 (Bankr. D. Iowa 2005). · cites it 2× “Iowa Code § 684.9 ; see also 684.7 (remedies of creditors).”
Jeannie Schlichte v. William Schlichte, Individually & as of the Est. of Gregory Schlichte, Dennis Schlichte, Jerome Schlichte, Joyce Ludwigs, & Cindy Berner-Schlichte (Iowa Ct. App. 2014). · cites it 4× “” Iowa Code § 684.9 (1). There is no dispute that Jeannie’s claim was brought more than five years after the transfer was made.”
Alice M. Shea v. Theresa Lorenz & Mark Lorenz, defendants-appellees/cross-appellants, & Kristin Ostrander, Valerie Bisanz, Thomas Lorenz, Heidi Lorenz, Rob E. Dickinson & R.E. Dickinson Inv. Advisors, LLC (Iowa Ct. App. 2015). · cites it 2× “The statute of limitations applicable to Alice’s claim here is found in Iowa Code section 684.9, and Theresa makes no claim that Alice is barred by this statute of limitations.”
In re the Est. of Glaser (Iowa Ct. App. 2020). “§ 684.9(1). So, Kindsfather argues, the amendment was too late to add a claim regarding Shreve’s transfer of the farm to Kindsfather on September 19, 2012, much less Glaser’s transfer of the farm to Shreve on September 9, 2011.”
Douglas King v. Daniel Wilson (Iowa Ct. App. 2014). “” Iowa Code § 684.9 (1) (2011). Here, the allegedly fraudulent transfer was Prairie Pork Farms’ sale to King in May 2005.”
— Iowa Code § 684.9(1) — 2 cases
Jeannie Schlichte v. William Schlichte, Individually & as of the Est. of Gregory Schlichte, Dennis Schlichte, Jerome Schlichte, Joyce Ludwigs, & Cindy Berner-Schlichte (Iowa Ct. App. 2014). “” Iowa Code § 684.9 (1). There is no dispute that Jeannie’s claim was brought more than five years after the transfer was made.”
In re the Est. of Glaser (Iowa Ct. App. 2020). “§ 684.9(1). So, Kindsfather argues, the amendment was too late to add a claim regarding Shreve’s transfer of the farm to Kindsfather on September 19, 2012, much less Glaser’s transfer of the farm to Shreve on September 9, 2011.”
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