Michigan Compiled Laws

Mich. Comp. Laws § 566.33 (2026)

Transfer for value.

✓ current as of July 2026

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UNIFORM VOIDABLE TRANSACTIONS ACT

Act 434 of 1998

566.33 Transfer for value.

Sec. 3.

(1) Value is given for a transfer or an obligation if, in exchange for the transfer or obligation, property is transferred or an antecedent debt is secured or satisfied. Value does not include an unperformed promise made otherwise than in the ordinary course of the promisor's business to furnish support to the debtor or another person.

(2) For the purposes of section 4(1)(b) and section 5, a person gives a reasonably equivalent value if the person acquires an interest of the debtor in an asset pursuant to a regularly conducted, noncollusive foreclosure sale or execution of a power of sale for the acquisition or disposition of the interest of the debtor upon default under a mortgage, deed of trust, or security agreement.

(3) A transfer is made for present value if the exchange between the debtor and the transferee is intended by them to be contemporaneous and is in fact substantially contemporaneous.

History: 1998, Act 434, Imd. Eff. Dec. 30, 1998 ;-- Am. 2016, Act 552, Eff. Apr. 10, 2017

Notes of Decisions

Cited in 19 cases (5 in the last 5 years), 2005–2026 · leading case: Nathan v. Libra (In re Libra), 584 B.R. 550 (Bankr. E.D. Mich. 2018).

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Nathan v. Libra (In re Libra), 584 B.R. 550 (Bankr. E.D. Mich. 2018). · cites it 5× “§ 566.33. Court ordered spousal support is enforceable pursuant to The Support and Parenting Time Enforcement Act, M.”

Madden v. Morelli (In re Energy Conversion Devices, Inc.), 548 B.R. 208 (Bankr. E.D. Mich. 2016). · cites it 6× “See Mich. Comp. Laws § 566.33 (1). 28 For these reasons, Plaintiffs constructive fraudulent transfer claims, with respect to both the May-2011 Transfer and the December 2011 Transfer, fail under *220 the Michigan fraudulent transfer statutes.”

Dillard v. Schlussel, 865 N.W.2d 648 (Mich. Ct. App. 2014). “[MCL 566.33.] The commentary to the uniform act provides: “Value” is to be determined in light of the purpose of the Act to protect a debtor’s estate from being depleted to the prejudice of the debtor’s unsecured creditors.”

Gold v. Marquette Univ. (In Re Leonard), 454 B.R. 444 (Bankr. E.D. Mich. 2011). · cites it 2× “See Mich. Comp. Laws § 566.33 (1). 22 Thus, “reasonably equivalent value” under the Michigan statute means the same thing that it does under Bankruptcy Code § 548.”

Simon v. Short (In re Oakland Physicians Med. Ctr., L.L.C.), 596 B.R. 587 (Bankr. E.D. Mich. 2019). · cites it 4× “§ 566.33. The Court concludes that the burden under M.”

Gold v. Winget (In Re NM Holdings Co.), 407 B.R. 232 (Bankr. E.D. Mich. 2009). “§ 566.33(1) "value is given for a transfer .”

Lewis v. Harlin (In Re Harlin), 321 B.R. 836 (E.D. Mich. 2005). “*840 § 566.33. The only significant difference in terms of a constructive fraudulent transfer is that “good faith” is no longer an element for determining whether a conveyance was made without receiving a reasonably equivalent value, i.”

Richardson v. Checker Acquisition Corp. (In re Checker Motors Corp.), 495 B.R. 355 (Bankr. W.D. Mich. 2013). · cites it 2× “§ 548 (a)(1)(B); Mich. Comp. Laws § 566.34 (l)(b). . 11 U.”

Pinnacle North LLC v. Keith a White (Mich. Ct. App. 2026). · cites it 3× “And as to the concept of “reasonably equivalent value in exchange for the transfer or obligation,” MCL 566.33 provides, in relevant part: (1) Value is given for a transfer or an obligation if, in exchange for the transfer or obligation, property is transferred or an antecedent…”

Meoli v. Cooper (In re Allen), 521 B.R. 613 (Bankr. W.D. Mich. 2014). “§ 566.33(1). . See M.C.L. § 566.31(c) (defining “claim”) and (d) ("debt”); see also 11 U.”

Schafer & Weiner Pllc v. Donald S Dreyfuss (Mich. Ct. App. 2021). · cites it 2× “Thus, in exchange for the CON, defendants were relieved of approximately $165,000 in debt.”

Can IV Packard Square LLC v. Craig Schubiner (Mich. Ct. App. 2024). · cites it 2× “The UVTA discusses value in MCL 566.33: (1) Value is given for a transfer or an obligation if, in exchange for the transfer or obligation, property is transferred or an antecedent debt is secured or satisfied.”

Show all 19 citing cases →

— Mich. Comp. Laws § 566.33(1) — 11 cases

Nathan v. Libra (In re Libra), 584 B.R. 550 (Bankr. E.D. Mich. 2018). “§ 566.33. Court ordered spousal support is enforceable pursuant to The Support and Parenting Time Enforcement Act, M.”

Gold v. Winget (In Re NM Holdings Co.), 407 B.R. 232 (Bankr. E.D. Mich. 2009). “§ 566.33(1) "value is given for a transfer .”

Madden v. Morelli (In re Energy Conversion Devices, Inc.), 548 B.R. 208 (Bankr. E.D. Mich. 2016). “See Mich. Comp. Laws § 566.33 (1). 28 For these reasons, Plaintiffs constructive fraudulent transfer claims, with respect to both the May-2011 Transfer and the December 2011 Transfer, fail under *220 the Michigan fraudulent transfer statutes.”

Simon v. Short (In re Oakland Physicians Med. Ctr., L.L.C.), 596 B.R. 587 (Bankr. E.D. Mich. 2019). “§ 566.33. The Court concludes that the burden under M.”

Meoli v. Cooper (In re Allen), 521 B.R. 613 (Bankr. W.D. Mich. 2014). “§ 566.33(1). . See M.C.L. § 566.31(c) (defining “claim”) and (d) ("debt”); see also 11 U.”

— Mich. Comp. Laws § 566.33(2) — 2 cases

Pinnacle North LLC v. Keith a White (Mich. Ct. App. 2026). “And as to the concept of “reasonably equivalent value in exchange for the transfer or obligation,” MCL 566.33 provides, in relevant part: (1) Value is given for a transfer or an obligation if, in exchange for the transfer or obligation, property is transferred or an antecedent…”

Weatherseal Home Improvements Inc v. Richard J Sable (Mich. Ct. App. 2014).

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