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

Mass. Gen. Laws ch. 109A, § 9 (2026)

Voidable transfers; creditor's judgment

✓ current as of July 2026
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Section 9. (a) A transfer or obligation is not voidable under paragraph (1) of subsection (a) of section five against a person who took in good-faith and for a reasonably equivalent value or against any subsequent transferee or obligee.

(b) Except as otherwise provided in this section, to the extent a transfer is voidable in an action by a creditor under paragraph (1) of subsection (a) of section eight, the creditor may recover judgment for the value of the asset transferred, as adjusted under subsection (c), or the amount necessary to satisfy the creditor's claim, whichever is less. The judgment may be entered against:

(1) the first transferee of the asset or the person for whose benefit the transfer was made; or

(2) any subsequent transferee other than a good-faith transferee or obligee who took for value or from any subsequent transferee or obligee.

(c) If the judgment under subsection (b) is based upon the value of the asset transferred, the judgment shall be for an amount equal to the value of the asset at the time of the transfer, subject to adjustment as the equities may require.

(d) Notwithstanding voidability of a transfer or an obligation under this chapter, a good-faith transferee or obligee is entitled, to the extent of the value given the debtor for the transfer or obligation, to

(1) a lien on or a right to retain any interest in the asset transferred;

(2) enforcement of any obligation incurred; or

(3) a reduction in the amount of the liability on the judgment.

(e) A transfer is not voidable under paragraph (2) of subsection (a) of section five or section six if the transfer results from:

(1) termination of a lease upon default by the debtor when the termination is pursuant to the lease and applicable law; or

(2) enforcement of a security interest in compliance with Article 9 of chapter one hundred and six.

(f) A transfer is not voidable under subsection (b) of section six:

(1) to the extent the insider gave new value to or for the benefit of the debtor after the transfer was made unless the new value was secured by a valid lien;

(2) if made in the ordinary course of business or financial affairs of the debtor and the insider; or

(3) if made pursuant to a good-faith effort to rehabilitate the debtor and the transfer secured present value given for that purpose as well as an antecedent debt of the debtor.

Notes of Decisions
Cited in 32 cases (1 in the last 5 years), 1977–2025 · leading case: Bakwin v. Mardirosian, 6 N.E.3d 1078 (Mass. 2014).
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Bakwin v. Mardirosian, 6 N.E.3d 1078 (Mass. 2014). · cites it 12× “” G. L. c. 109A, § 9 (b), (c). Bakwin argues that the judge erred by ordering a judgment *636 providing for avoidance of the transfer and attachment of Robert’s interest, rather than a money judgment against Madeline.”
Frank Sawyer Trust of May 1992 v. Comm'r of Internal Reven, 712 F.3d 597 (1st Cir. 2013). · cites it 3× “” Mass. Gen. Laws ch. 109A, § 9(d); accord Unif.”
Foster v. Evans, 429 N.E.2d 995 (Mass. 1981). · cites it 3× “Evans, pursuant to G. L. c. 109A, § 9 (1) (b), cannot thereafter proceed in equity under § 9 (1) (a) to have the deed to Mary P.”
Foisie v. Worcester Polytechnic Inst., 967 F.3d 27 (1st Cir. 2020). “Both Massachusetts and Connecticut permit a transferee to assert as a defense to the avoidance of actually fraudulent transfers that it received the transfer "in good faith and for a reasonably equivalent value.”
Nader v. Citron, 360 N.E.2d 870 (Mass. 1977). “G. L. c. 109A, § 9. The plaintiff seeks treble damages and attorneys’ fees under G.”
Ferrari v. Barclays Bus. Credit, Inc. (In Re Morse Tool, Inc.), 148 B.R. 97 (Bankr. D. Mass. 1992). · cites it 3× “Stretching the Trade; G.L. c. 109A, § 9(1) 40. On the basis of what occurred after the buyout, it is clear that, when Lambert entered into the buyout, he intended to stretch trade payables to well beyond thirty and sixty days.”
N. Parent, Inc. v. Cotter & Co. (In Re N. Parent, Inc.), 221 B.R. 609 (Bankr. D. Mass. 1998). · cites it 2× “In brief, the Debtor maintains that after the Chicopee store closed in 1992, Cotter made representations to the Debtor to the effect that if the Debtor did not seek bankruptcy protection and continued to pay Cotter money owed on the Chicopee store debt, Cotter would continue to…”
Mullane v. Chambers, 333 F.3d 322 (1st Cir. 2003). “Mullane was a bona fide purchaser for value without notice of any adverse claims to the vessel and thus concluded that whether the underlying transaction was fraudulent was immaterial.”
Feinman v. Messia (In Re Messia), 184 B.R. 176 (Bankr. D. Mass. 1995). · cites it 3× “§ 548 (a)(1), § 544(b), M.G.L. c. 109A, §§ 9 and 10, and 11 U.S.C.”
Branch v. Fed. Deposit Ins., 825 F. Supp. 384 (D. Mass. 1993). “§§ 548 , 550; see also Mass.Gen.L. ch. 109A § 9(l)(a) (incorporated into Branch’s Bankruptcy Code claims via section 544[b]).”
Murphy v. Meritor Sav. Bank (In Re O'Day Corp.), 126 B.R. 370 (Bankr. D. Mass. 1991). “Mass.Gen.Laws Ann. ch. 109A, § 9 (West 1990).”
Northborough Nat'l Bank v. Risley, 424 N.E.2d 522 (Mass. 1981). · cites it 2× “Thus the transfer was fraudulent under G.L.c. 109A, § 7, as a transfer "with actual intent .”
Show all 32 citing cases →
— Mass. Gen. Laws ch. 109A, § 9(1) — 3 cases
Ferrari v. Barclays Bus. Credit, Inc. (In Re Morse Tool, Inc.), 148 B.R. 97 (Bankr. D. Mass. 1992). “Stretching the Trade; G.L. c. 109A, § 9(1) 40. On the basis of what occurred after the buyout, it is clear that, when Lambert entered into the buyout, he intended to stretch trade payables to well beyond thirty and sixty days.”
Citizens Bank v. Callahan, 653 N.E.2d 600 (Mass. App. Ct. 1995).
Salem v. Glynn, 5 Mass. L. Rptr. 656 (Mass. Super. Ct. 1996).
— Mass. Gen. Laws ch. 109A, § 9(1)(a) — 1 case
Demogenes v. Welch, 2 Mass. L. Rptr. 186 (Mass. Super. Ct. 1994).
— Mass. Gen. Laws ch. 109A, § 9(2) — 1 case
Ferrari v. Barclays Bus. Credit, Inc. (In Re Morse Tool, Inc.), 148 B.R. 97 (Bankr. D. Mass. 1992). “Stretching the Trade; G.L. c. 109A, § 9(1) 40. On the basis of what occurred after the buyout, it is clear that, when Lambert entered into the buyout, he intended to stretch trade payables to well beyond thirty and sixty days.”
— Mass. Gen. Laws ch. 109A, § 9(A)(2) — 1 case
Rivera v. Club Caravan, Inc., 928 N.E.2d 348 (Mass. App. Ct. 2010).
— Mass. Gen. Laws ch. 109A, § 9(a) — 2 cases
Foisie v. Worcester Polytechnic Inst., 967 F.3d 27 (1st Cir. 2020). “Both Massachusetts and Connecticut permit a transferee to assert as a defense to the avoidance of actually fraudulent transfers that it received the transfer "in good faith and for a reasonably equivalent value.”
Cheswell, Inc. v. Premier Homes & Land Corp., 319 F. Supp. 2d 135 (D. Mass. 2004).
— Mass. Gen. Laws ch. 109A, § 9(b) — 5 cases
Cruickshank v. Dixon (In re Blast Fitness Grp., LLC), 602 B.R. 208 (Bankr. D. Mass. 2019).
Cruickshank v. Dixon (In re Blast Fitness Grp., LLC), 603 B.R. 219 (Bankr. D. Mass. 2019).
Mass Printing & Forms, Inc. v. RKS Health Ventures Corp., 11 Mass. L. Rptr. 755 (Mass. Super. Ct. 2000).
Belegu (D. Mass. 2025).
Cruickshank v. Dixon (Bankr. D. Mass. 2020).
— Mass. Gen. Laws ch. 109A, § 9(b)(1) — 2 cases
S. New England Tel. Co. v. Global Naps, Inc., 595 F. Supp. 2d 155 (D. Mass. 2009).
Belegu (D. Mass. 2025).
— Mass. Gen. Laws ch. 109A, § 9(d) — 1 case
Frank Sawyer Trust of May 1992 v. Comm'r of Internal Reven, 712 F.3d 597 (1st Cir. 2013). “” Mass. Gen. Laws ch. 109A, § 9(d); accord Unif.”
— Mass. Gen. Laws ch. 109A, § 9(l)(a) — 3 cases
Branch v. Fed. Deposit Ins., 825 F. Supp. 384 (D. Mass. 1993). “§§ 548 , 550; see also Mass.Gen.L. ch. 109A § 9(l)(a) (incorporated into Branch’s Bankruptcy Code claims via section 544[b]).”
Citizens Bank v. Callahan, 653 N.E.2d 600 (Mass. App. Ct. 1995).
Demogenes v. Welch, 2 Mass. L. Rptr. 186 (Mass. Super. Ct. 1994).
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