Minn. Stat. » CHAPTER 513. AGREEMENTS RELATING TO PROPERTY
Minnesota Statutes

Minn. Stat. § 513.43 (2026)

Value

✓ current as of May 2026
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(a) 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, but 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.

(b) For the purposes of section 513.44, paragraph (a), clause (2), and section 513.45, 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, security agreement, or agricultural lien.

(c) 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.

Notes of Decisions
Cited in 18 cases, 1990–2020 · leading case: Citizens State Bank Norwood Young Am. v. Gordon Brown, 849 N.W.2d 55 (Minn. 2014).
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Citizens State Bank Norwood Young Am. v. Gordon Brown, 849 N.W.2d 55 (Minn. 2014). · cites it 4× “” Minn. Stat. § 513.43 (a). The Browns do not argue that any debt was secured or satisfied pursuant to the divorce.”
In Re Butler, 552 N.W.2d 226 (Minn. 1996). · cites it 6× “Minn.Stat. § 513.43(b). The prefatory note to the Uniform Act makes a distinction between the transfer of an unencumbered property and the transfer of property which served as security for a debt.”
Kelley v. Associated Bank (In re Petters Co.), 548 B.R. 551 (Bankr. D. Minn. 2016). · cites it 4× “The Finn court concluded that “any legally enforceable right to payment against the debtor is sufficient to qualify as an antecedent debt under MUFTA” for the purposes of the definition of “value” under Minn.Stat. § 513.43(a). 860 N.W.2d at 651 .”
Finn v. All. Bank, 860 N.W.2d 638 (Minn. 2015). · cites it 2× “§ 513.43(a). As MUFTA’s text and our cases confirm, deciding whether a debtor has received reasonably equivalent value is a function of the relative value received by the debtor in the underlying exchange.”
In re Petters Co., Inc., 495 B.R. 887 (Bankr. D. Minn. 2013). · cites it 2× “” See, in pertinent part, Minn. Stat. § 513.43 (a) ("Value is given for a transfer .”
Douglas A. Kelley v. Gus Boosalis, 974 F.3d 884 (8th Cir. 2020). · cites it 2× “Consistent with Minn. Stat. § 513.43 (a), the Court held that “the satisfaction of an antecedent debt can constitute reasonably equivalent value” and “any legally enforceable right to payment against the debtor is sufficient to qualify as an antecedent debt under MUFTA.”
Citizens State Bank of Hayfield v. Leth, 450 N.W.2d 923 (Minn. Ct. App. 1990). · cites it 2× “There was no substantially contemporaneous exchange of value as required by Minn.Stat. § 513.43(c). The downpayment was a nullity, since it was given by Erling and Catherine to Donald.”
Ritchie Capital Mgmt. v. John Stoebner, 779 F.3d 857 (8th Cir. 2015). “See Minn.Stat. § 513.43(a) (“Value is given for a transfer .”
Finn v. All. Bank, 838 N.W.2d 585 (Minn. Ct. App. 2013). · cites it 2× “10 Minn.Stat. § 513.43(a). Here, the record establishes that Alliance purchased a participation interest in a loan made by First United to a legitimate borrower and that the borrower repaid First United the loan principal, plus required interest and fees.”
Christians v. Crystal Evangelical Free Church ( in Re Young), 148 B.R. 886 (Bankr. D. Minn. 1992). · cites it 2× “651 comment 3; Minn. Stat. § 513.43 (1992) (adopting and codifying as state law the Uniform Fraudulent Transfers Act); see generally, Peter A.”
Kaye v. Nath Companies (In re Duke & King Acquisition Corp.), 508 B.R. 107 (Bankr. D. Minn. 2014). · cites it 2× “Minn.Stat. § 513.43(a), and [flair consideration is given for property .”
Elliot & Callan, Inc. v. Crofton, 615 F. Supp. 2d 963 (D. Minnesota 2009). · cites it 2× “Minn.Stat. § 513.43(a). Thus, “value” includes “property,” which would obviously include the money that Crofton loaned or advanced to SCC.”
Show all 18 citing cases →
— Minn. Stat. § 513.43(a) — 8 cases
Finn v. All. Bank, 860 N.W.2d 638 (Minn. 2015). “§ 513.43(a). As MUFTA’s text and our cases confirm, deciding whether a debtor has received reasonably equivalent value is a function of the relative value received by the debtor in the underlying exchange.”
Citizens State Bank Norwood Young Am. v. Gordon Brown, 849 N.W.2d 55 (Minn. 2014). “” Minn. Stat. § 513.43 (a). The Browns do not argue that any debt was secured or satisfied pursuant to the divorce.”
Kelley v. Associated Bank (In re Petters Co.), 548 B.R. 551 (Bankr. D. Minn. 2016). “The Finn court concluded that “any legally enforceable right to payment against the debtor is sufficient to qualify as an antecedent debt under MUFTA” for the purposes of the definition of “value” under Minn.Stat. § 513.43(a). 860 N.W.2d at 651 .”
Ritchie Capital Mgmt. v. John Stoebner, 779 F.3d 857 (8th Cir. 2015). “See Minn.Stat. § 513.43(a) (“Value is given for a transfer .”
Finn v. All. Bank, 838 N.W.2d 585 (Minn. Ct. App. 2013). “10 Minn.Stat. § 513.43(a). Here, the record establishes that Alliance purchased a participation interest in a loan made by First United to a legitimate borrower and that the borrower repaid First United the loan principal, plus required interest and fees.”
— Minn. Stat. § 513.43(a)(2012) — 1 case
Kelley v. Associated Bank (In re Petters Co.), 548 B.R. 551 (Bankr. D. Minn. 2016). “The Finn court concluded that “any legally enforceable right to payment against the debtor is sufficient to qualify as an antecedent debt under MUFTA” for the purposes of the definition of “value” under Minn.Stat. § 513.43(a). 860 N.W.2d at 651 .”
— Minn. Stat. § 513.43(b) — 2 cases
In Re Butler, 552 N.W.2d 226 (Minn. 1996). “Minn.Stat. § 513.43(b). The prefatory note to the Uniform Act makes a distinction between the transfer of an unencumbered property and the transfer of property which served as security for a debt.”
Shields v. Goldetsky, 552 N.W.2d 226 (Minn. 1996).
— Minn. Stat. § 513.43(c) — 1 case
Citizens State Bank of Hayfield v. Leth, 450 N.W.2d 923 (Minn. Ct. App. 1990). “There was no substantially contemporaneous exchange of value as required by Minn.Stat. § 513.43(c). The downpayment was a nullity, since it was given by Erling and Catherine to Donald.”
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