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Kansas Statutes Annotated

K.S.A. § 33-207 (2026)

Remedies of creditors

✓ current as of May 2026
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33-207. Remedies of creditors. (a) In an action for relief against a transfer or obligation under this act, a creditor, subject to the limitations in K.S.A. 33-208, may obtain:

(1) Avoidance of the transfer or obligation to the extent necessary to satisfy the creditor's claim;

(2) an attachment or other provisional remedy against the asset transferred or other property of the transferee in accordance with the procedure prescribed by K.S.A. 60-701 et seq., and amendments thereto, or other appropriate provision of law;

(3) subject to applicable principles of equity and in accordance with applicable rules of civil procedure:

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

(B) appointment of a receiver to take charge of the asset transferred or of other property of the transferee; or

(C) any other relief the circumstances may require.

(b) 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.

History: L. 1998, ch. 13, § 7; January 1, 1999.

Notes of Decisions
Cited in 13 cases (3 in the last 5 years), 2002–2025 · leading case: Redmond v. NCMIC Fin. Corp. (In re Brooke Corp.), 488 B.R. 459 (Bankr. D. Kan. 2013).
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Redmond v. NCMIC Fin. Corp. (In re Brooke Corp.), 488 B.R. 459 (Bankr. D. Kan. 2013). · cites it 4× “Recovery from NCMIC is sought under Bankruptcy § 550 and K.S.A. 33-207, as the initial transferee or a subsequent transferee.”
McCain Foods USA, Inc. v. Cent. Processors, Inc., 61 P.3d 68 (Kan. 2002). “K.S.A. 33-207(a)(l) (the remedy selected by McCain here).”
Redmond v. Gulf City Body & Trailer Works, Inc. (In Re Sunbridge Capital, Inc.), 454 B.R. 166 (Bankr. D. Kan. 2011). · cites it 2× “§ 550 and K.S.A. § 33-207. When moving to dismiss, Defendant states it resides in the Southern District of Alabama and has no place of business, office, or branch in the State of Kansas.”
Redmond v. Brooke Holdings, Inc. (In re Brooke Corp.), 515 B.R. 632 (Bankr. D. Kan. 2014). “33-204(a)(2) and 33-205(a)) and § 548(a)(1)(B); and (3) pursuant to § 550 and K.S.A. 33-207, the Trustee may recover the $5,100,800 and $13,143,980.”
Redmond v. SpiritBank (In re Brooke Corp.), 541 B.R. 492 (Bankr. D. Kan. 2015). “Count IV seeks recovery from SpiritBank of all avoided transfers under § 550 and K.S.A. 33-207. Count V is a claim objection cause of action seeking disallowance of SpiritBank’s claim under § 502(d).”
Redmond v. NCMIC Fin. Corp. (In re Brooke Corp.), 568 B.R. 378 (Bankr. D. Kan. 2017). “K.S.A. 33-207 provides for remedies similar to those allowed under § 550.”
Riederer v. Logan Wildlife Corp. (In Re Brooke Corp.), 443 B.R. 847 (Bankr. D. Kan. 2010). “K.S.A. 33-207 of the Kansas Fraudulent Transfer Act addresses remedies in part as follows: (a) In an action for relief against a transfer or obligation under this act, a creditor, subject to the limitations in K.”
Redmond v. Progressive Corp. (In re Brooke Corp.), 469 B.R. 68 (D. Kan. 2012). · cites it 2× “§ 550 and K.S.A. § 33-207. Defendant’s sole argument relating to Count III is that it should also be dismissed if Counts I and II, on which it depends, are dismissed.”
Harder v. Foster (Kan. Ct. App. 2017). · cites it 10× “"Claim" is defined as "a right to payment, whether or not the right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured or unsecured.”
Consum. Fin. Prot. Bureau v. Carnes (D. Kan. 2023). · cites it 2× “Nonetheless, the creditor sued defendants for fraudulent transfer and relied on Kan. Stat. Ann. § 33-207 (a)(3)(C), which, like 28 U.”
Digit. Ally, Inc. v. Culp McAuley, Inc. (D. Kan. 2024). · cites it 2× “The remedies available under KUFTA are limited: subsection (a) of K.S.A. 33-207 provides remedies only against transfers, obligations, and assets, that is in rem relief (relief against property).”
Holman v. Future Growth, LLC (D. Kan. 2025). · cites it 2× “In Count III, Plaintiffs seek injunctive relief under K.S.A. § 33-207, asking the Court to either (1) avoid the real estate transfer that took place on August 28, 2023, between Future Growth and STUGA or (2) prohibit the further transfer of the real estate pending the outcome of…”
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— K.S.A. § 33-207(a)(3)(C) — 2 cases
Harder v. Foster (Kan. Ct. App. 2017). “"Claim" is defined as "a right to payment, whether or not the right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured or unsecured.”
Digit. Ally, Inc. v. Culp McAuley, Inc. (D. Kan. 2024). “The remedies available under KUFTA are limited: subsection (a) of K.S.A. 33-207 provides remedies only against transfers, obligations, and assets, that is in rem relief (relief against property).”
— K.S.A. § 33-207(a)(3)(c) — 1 case
Harder v. Foster (Kan. Ct. App. 2017). “"Claim" is defined as "a right to payment, whether or not the right is reduced to judgment, liquidated, unliquidated, fixed, contingent, matured, unmatured, disputed, undisputed, legal, equitable, secured or unsecured.”
— K.S.A. § 33-207(a)(l) — 1 case
McCain Foods USA, Inc. v. Cent. Processors, Inc., 61 P.3d 68 (Kan. 2002). “K.S.A. 33-207(a)(l) (the remedy selected by McCain here).”
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