Massachusetts General Laws

Mass. Gen. Laws ch. 109A, § 6 (2026)

Fraudulent transfer or obligation where creditor's claim arose before transfer or obligation

✓ current as of July 2026
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Section 6. (a) A transfer made or obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without receiving a reasonably equivalent value in exchange for the transfer or obligation and the debtor was insolvent at that time or the debtor became insolvent as a result of the transfer or obligation.

(b) A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the insider had reasonable cause to believe that the debtor was insolvent.

Notes of Decisions
Cited in 37 cases, 1988–2020 · leading case: Lassman v. Sergio (In re Sergio), 552 B.R. 9 (Bankr. D. Mass. 2016).
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Lassman v. Sergio (In re Sergio), 552 B.R. 9 (Bankr. D. Mass. 2016). · cites it 11× “The applicable law here is Mass. Gen. Laws ch. 109A, § 6. Section 6 may only be invoked by “creditors] whose claim[s] arose before the transfer was made[.”
Foisie v. Worcester Polytechnic Inst., 967 F.3d 27 (1st Cir. 2020). · cites it 3× “§ 52 -552e(a)(2); Mass. Gen. Laws ch. 109A, § 5(a)(2), or to analogous claims of constructive fraudulent transfer, see Conn.”
Butler v. Wojtkun (In re Wojtkun), 534 B.R. 435 (Bankr. D. Mass. 2015). · cites it 11× “109A, § 5(a)(1); (9) avoidance of transfers of income from the Debtor to Susan pursuant to Mass. Gen. Laws ch. 109A, § 6(a); (10) avoidance of transfers of income from the Debtor to Susan pursuant to Mass.”
Tomsic v. Pitocchelli (In Re Tri-Star Tech. Co.), 260 B.R. 319 (Bankr. D. Mass. 2001). · cites it 3× “After conversion, the Trustee was substituted as plaintiff and added additional claims under § 544(b) of the Bankruptcy Code and Mass. Gen. Laws Ann. ch. 109A, § 6(a). The complaint was subsequently amended for a second time, adding a breach of contract claim.”
Riley v. Countrywide Home Loans, Inc. (In re Duplication Mgmt., Inc.), 501 B.R. 462 (Bankr. D. Mass. 2013). · cites it 4× “§ 544 (a)(1) and Mass. Gen. Laws ch. 109A, § 6, in the amount of $287,040.”
Fed. Refinance Co. v. Klock, 352 F.3d 16 (1st Cir. 2003). · cites it 2× “The UFTA provides in pertinent part: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the insider had reasonable…”
DeGiacomo v. Tobins (In re Upper Crust, LLC), 554 B.R. 23 (Bankr. D. Mass. 2016). · cites it 5× “§ 544 (b) and Mass. Gen. Laws ch. 109A, § 5(a)(2) (Count IV); 5) avoidance of the Four-Year Transfer's to Jordan under 11 U.”
Hasbro, Inc. v. Serafino, 37 F. Supp. 2d 94 (D. Mass. 1999). · cites it 5× “This statute, Mass.Gen.Laws ch. 109A, § 6(b), provides in part: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the…”
Lassman v. Reilly (In Re Feeley), 429 B.R. 56 (Bankr. D. Mass. 2010). · cites it 2× “See Mass. Gen. Laws ch. 109A, § 6(a), which provides: A transfer made or obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation…”
DeGiacomo v. Raymond C. Green, Inc. (In re Inofin Inc.), 512 B.R. 19 (Bankr. D. Mass. 2014). · cites it 2× “§ 544 (b) and M.G.L. c. 109A § 6(a)— Security Documents); Count XIII (Fraudulent Transfer Pursuant to 11 U.”
Braunstein v. Walsh (In Re Rowanoak Corp.), 344 F.3d 126 (1st Cir. 2003). “See Mass. Gen. Laws ch. 109A, § 6 (transfer is fraudulent under § 6(a) "if the debtor made the transfer or incurred the obligation without receiving a reasonably equivalent value in exchange for the transfer or obligation and .”
Blacksmith Investments, LLC v. Woodford (In Re Woodford), 403 B.R. 177 (Bankr. D. Mass. 2009). “The statute provides: (a) A transfer made or obligation incurred by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without receiving a reasonably…”
Show all 37 citing cases →
— Mass. Gen. Laws ch. 109A, § 6(a) — 18 cases
Foisie v. Worcester Polytechnic Inst., 967 F.3d 27 (1st Cir. 2020). “§ 52 -552e(a)(2); Mass. Gen. Laws ch. 109A, § 5(a)(2), or to analogous claims of constructive fraudulent transfer, see Conn.”
Tomsic v. Pitocchelli (In Re Tri-Star Tech. Co.), 260 B.R. 319 (Bankr. D. Mass. 2001). “After conversion, the Trustee was substituted as plaintiff and added additional claims under § 544(b) of the Bankruptcy Code and Mass. Gen. Laws Ann. ch. 109A, § 6(a). The complaint was subsequently amended for a second time, adding a breach of contract claim.”
Lassman v. Sergio (In re Sergio), 552 B.R. 9 (Bankr. D. Mass. 2016). “The applicable law here is Mass. Gen. Laws ch. 109A, § 6. Section 6 may only be invoked by “creditors] whose claim[s] arose before the transfer was made[.”
Butler v. Wojtkun (In re Wojtkun), 534 B.R. 435 (Bankr. D. Mass. 2015). “109A, § 5(a)(1); (9) avoidance of transfers of income from the Debtor to Susan pursuant to Mass. Gen. Laws ch. 109A, § 6(a); (10) avoidance of transfers of income from the Debtor to Susan pursuant to Mass.”
DeGiacomo v. Tobins (In re Upper Crust, LLC), 554 B.R. 23 (Bankr. D. Mass. 2016). “§ 544 (b) and Mass. Gen. Laws ch. 109A, § 5(a)(2) (Count IV); 5) avoidance of the Four-Year Transfer's to Jordan under 11 U.”
— Mass. Gen. Laws ch. 109A, § 6(b) — 6 cases
Fed. Refinance Co. v. Klock, 352 F.3d 16 (1st Cir. 2003). “The UFTA provides in pertinent part: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the insider had reasonable…”
Butler v. Wojtkun (In re Wojtkun), 534 B.R. 435 (Bankr. D. Mass. 2015). “109A, § 5(a)(1); (9) avoidance of transfers of income from the Debtor to Susan pursuant to Mass. Gen. Laws ch. 109A, § 6(a); (10) avoidance of transfers of income from the Debtor to Susan pursuant to Mass.”
Hasbro, Inc. v. Serafino, 37 F. Supp. 2d 94 (D. Mass. 1999). “This statute, Mass.Gen.Laws ch. 109A, § 6(b), provides in part: A transfer made by a debtor is fraudulent as to a creditor whose claim arose before the transfer was made if the transfer was made to an insider for an antecedent debt, the debtor was insolvent at that time, and the…”
Fed. Refinance Co., Inc. v. Klock, 229 F. Supp. 2d 26 (D. Mass. 2002).
Raso v. Fahey (In re Fahey), 494 B.R. 16 (Bankr. D. Mass. 2013).
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