Mass. Gen. Laws » Part I Title XV Chapter 109A
Massachusetts General Laws

Mass. Gen. Laws ch. 109A, § 10 (2026)

Limitation of actions

✓ current as of July 2026
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Section 10. A cause of action with respect to a fraudulent transfer or obligation under this chapter shall be extinguished unless action is brought:

(a) under paragraph (1) of subsection (a) of section five, 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 by the claimant;

(b) under paragraph (2) of subsection (a) of section five or subsection (a) of section six, within four years after the transfer was made or the obligation was incurred; or

(c) under subsection (b) of section six, within one year after the transfer was made or the obligation was incurred.

Notes of Decisions
Cited in 19 cases (2 in the last 5 years), 1975–2024 · leading case: Cavadi v. DeYeso, 941 N.E.2d 23 (Mass. 2011).
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Cavadi v. DeYeso, 941 N.E.2d 23 (Mass. 2011). · cites it 3× “This action requires us to consider whether a non-statutory action to reach and apply permits a creditor to pursue equitable assets of a debtor after the statute of limitations contained in G. L. c. 109A, § 10, has run. Jules R. Cavadi, both individually and as assignee of the…”
Sears Petroleum & Transp. Corp. v. Burgess Constr. Servs., Inc., 417 F. Supp. 2d 212 (D. Mass. 2006). · cites it 2× “As set forth above, Section 548 clearly contains a one-year statute of limitations whereas Section 544 relies on “applicable law” which here is the UFTA. The UFTA provides that a claim for fraudulent transfer must be brought within four years after the transfer was made or the…”
Kraft Power Corp. v. Merrill, 981 N.E.2d 671 (Mass. 2013). “” G. L. c. 109A, § 10. The UFTA states that a “transfer made.”
Tomsic v. Pitocchelli (In Re Tri-Star Tech. Co.), 260 B.R. 319 (Bankr. D. Mass. 2001). “1997); Mass. Gen. Laws Ann. ch. 109A, § 10. Section 548(a)(1)(B), on the other hand, reaches back only to those transfers made within one year of case commencement.”
Cruickshank v. Dixon (In re Blast Fitness Grp., LLC), 603 B.R. 219 (Bankr. D. Mass. 2019). · cites it 2× “See Mass. Gen. Laws ch. 109A, § 10. *233 With respect to the trustee's allegations that BFG transferred profitable clubs for little or no consideration to Lexfit and Newfit, some of which were later sold to Mr.”
Riley v. Countrywide Home Loans, Inc. (In re Duplication Mgmt., Inc.), 501 B.R. 462 (Bankr. D. Mass. 2013). “1997); Mass. Gen. Laws Ann. ch. 109A, § 10. Section 548(a)(1)(B), on the other hand, reaches back only to those transfers made within one year [now two years] of case commencement.”
Cruickshank v. Dixon (In re Blast Fitness Grp., LLC), 602 B.R. 208 (Bankr. D. Mass. 2019). “" Mass. Gen. Laws ch. 109A, § 10(a) and (b).”
Carpenter v. Granderson (In Re Granderson), 214 B.R. 671 (Bankr. D. Mass. 1997). “Mass. Gen. Laws Ann. ch. 109A, § 10. 2 . Section 2 provides in relevant part the following: Actions of contract, other than those to recover for personal injuries, founded upon contracts or liabilities, express or implied, except actions limited by section one or actions upon…”
Am. Velodur Metal, Inc. v. Schinabeck, 481 N.E.2d 209 (Mass. App. Ct. 1985). “7 Judge D dismissed AVM’s complaint and directed that the Scituate premises be treated as having been the subject of a fraudulent conveyance (G. L. c. 109A, § 10). Judge D’s original intention apparently was that the Scituate premises be reconveyed by AVM to Schinabeck and the…”
Billingham v. Simpson (In Re Simpson), 334 B.R. 298 (Bankr. D. Mass. 2005). · cites it 2× “§ 548 (a), which permits a bankruptcy trustee to avoid a transfer that occurred at most one year before the date of the bankruptcy petition, 3 or, if the Trustee is proceeding under state law, then by the four-year limitations period in § 10 of the Uniform Fraudulent Transfer…”
Desmond v. Chiang (In re Chiang), 562 B.R. 559 (Bankr. D. Mass. 2016). · cites it 2× “See Mass. Gen. Laws ch. 109A, § 10. 9 *569 The Trustee contends that the Transfer may be avoided under Mass.”
Rafuse v. Stryker, 27 Mass. L. Rptr. 95 (Mass. Super. Ct. 2010). · cites it 3× “” See G.L.c. 109A, §10. There was no similar section in the UFCA.”
Show all 19 citing cases →
— Mass. Gen. Laws ch. 109A, § 10(a) — 3 cases
Cruickshank v. Dixon (In re Blast Fitness Grp., LLC), 602 B.R. 208 (Bankr. D. Mass. 2019). “" Mass. Gen. Laws ch. 109A, § 10(a) and (b).”
Cruickshank v. Dixon (In re Blast Fitness Grp., LLC), 603 B.R. 219 (Bankr. D. Mass. 2019). “See Mass. Gen. Laws ch. 109A, § 10. *233 With respect to the trustee's allegations that BFG transferred profitable clubs for little or no consideration to Lexfit and Newfit, some of which were later sold to Mr.”
Billingham v. Simpson (In Re Simpson), 334 B.R. 298 (Bankr. D. Mass. 2005). “§ 548 (a), which permits a bankruptcy trustee to avoid a transfer that occurred at most one year before the date of the bankruptcy petition, 3 or, if the Trustee is proceeding under state law, then by the four-year limitations period in § 10 of the Uniform Fraudulent Transfer…”
— Mass. Gen. Laws ch. 109A, § 10(b) — 3 cases
Rafuse v. Stryker, 27 Mass. L. Rptr. 95 (Mass. Super. Ct. 2010). “” See G.L.c. 109A, §10. There was no similar section in the UFCA.”
Jae Corp. v. Mass. Port Realty Co., 3 Mass. App. Ct. 704 (Mass. App. Ct. 1975).
Jiajing (Beijing) Tourism Co., Ltd v. Kaplan (D. Mass. 2024).
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