Nevada Revised Statutes

Nev. Rev. Stat. § 112.190 (2026)

Transfer made or obligation incurred by insolvent

✓ current as of July 2026
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NRS 112.190  Transfer made or obligation incurred by insolvent.

      1.  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.

      2.  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.

      (Added to NRS by 1987, 11)

     

Notes of Decisions
Cited in 25 cases (5 in the last 5 years), 1996–2026 · leading case: Wells Fargo Bank, N.A. v. Radecki, 426 P.3d 593 (Nev. 2018).
Wells Fargo Bank, N.A. v. Radecki, 426 P.3d 593 (Nev. 2018). · cites it 4× “180(1)(b)(2) applicable, because there was no evidence that the homeowner "[i]ntended to incur, or believed or reasonably should have believed that [she] would incur, debts beyond .”
Herup v. First Boston Fin., LLC, 162 P.3d 870 (Nev. 2007). · cites it 3× “13 NRS 112.190. A fraudulent transfer by an insolvent debtor occurs in two situations: (1) when the debtor makes the transfer without receiving a reasonably equivalent value in exchange for the transfer and the debtor was insolvent at that time or the debtor became insolvent as…”
Sportsco Enter. v. Morris, 917 P.2d 934 (Nev. 1996). · cites it 4× “Pursuant to NRS 112.190(1), where a creditor's claim arose before a transfer made by a debtor, the transfer is fraudulent if the debtor did not receive "reasonably equivalent value in exchange" and was insolvent at the time of making the transfer or became so as a result of the…”
Guild Mortg. Co. v. Prestwick Court Trust, 293 F. Supp. 3d 1228 (D. Nev. 2018). · cites it 5× “" Nev. Rev. Stat. § 112.190 (1). NRS 112.150(12) defines transfer as "every mode, direct or indirect, absolute or conditional, voluntary or involuntary, or disposing of or parting with an asset or an interest in an asset, and includes payment of money, release, lease and…”
ShengdaTech Liquidating Trust v. Hansen (In re Shengdatech, Inc.), 519 B.R. 292 (D. Nev. 2014). · cites it 2× “180(l)(b) of the Act pertains to constructive fraudulent transfers while section 112.190 applies to transfers made by insolvent debtors.”
Wells Fargo Bank, N.A. Vs. Radecki, 2018 NV 74 (Nev. 2018). · cites it 8× “180(1)(b)(2), and NRS 112.190(1). NRS 112.180(1)(b)(1) does not apply, because there was no evidence that the homeowner "[w] as engaged or was about to engage in a business or a transaction for which the remaining assets of the debtor were unreasonably small.”
Wells Fargo Bank, N.A. Vs. Radecki, 2018 NV 74 (Nev. 2018). · cites it 8× “180(1)(b)(2), and NRS 112.190(1). NRS 112.180(1)(b)(1) does not apply, because there was no evidence that the homeowner "[w] as engaged or was about to engage in a business or a transaction for which the remaining assets of the debtor were unreasonably small.”
Bock, LLC v. Steelman (D. Nev. 2020). · cites it 5× “180(1) and NRS § 112.190(1). Bock also alleges the same claims 9 against Suzanne and Stephen (the Steelmans’ adult children), arguing that they accepted the 10 transfers to shield those funds and assets from Bock’s post-judgment collection efforts.”
Razaghi (D. Nev. 2025). · cites it 4× “NRS 112.190 8 Plaintiff must show the following to be successful under its NRS 112.”
Winkler (D. Nev. 2026). · cites it 3× “180(1)(a–b) and NRS 112.190. (See ECF No. 1 at 11). Nevada’s Uniform Fraudulent Transfer 13 Act provides limitations on actions brought for fraudulent transfers.”
Bizzaro v. Half Dental Franchise, LLC (Nev. 2018). · cites it 2× “190 (Nevada's Uniform Fraudulent Transfer Act) and asked for declaratory judgment to the same effect.”
Ncp Bayou 2, LLC v. Medici C/W 73122 (Nev. 2019). · cites it 2× “180(1)(a)-(b); NRS 112.190. The uniting factor for each of these transfers is that it is the debtor who SUPREME COURT OF NEVADA 2 i.”
— Nev. Rev. Stat. § 112.190(1) — 20 cases
Wells Fargo Bank, N.A. v. Radecki, 426 P.3d 593 (Nev. 2018). “180(1)(b)(2) applicable, because there was no evidence that the homeowner "[i]ntended to incur, or believed or reasonably should have believed that [she] would incur, debts beyond .”
Sportsco Enter. v. Morris, 917 P.2d 934 (Nev. 1996). “Pursuant to NRS 112.190(1), where a creditor's claim arose before a transfer made by a debtor, the transfer is fraudulent if the debtor did not receive "reasonably equivalent value in exchange" and was insolvent at the time of making the transfer or became so as a result of the…”
Herup v. First Boston Fin., LLC, 162 P.3d 870 (Nev. 2007). “13 NRS 112.190. A fraudulent transfer by an insolvent debtor occurs in two situations: (1) when the debtor makes the transfer without receiving a reasonably equivalent value in exchange for the transfer and the debtor was insolvent at that time or the debtor became insolvent as…”
Guild Mortg. Co. v. Prestwick Court Trust, 293 F. Supp. 3d 1228 (D. Nev. 2018). “" Nev. Rev. Stat. § 112.190 (1). NRS 112.150(12) defines transfer as "every mode, direct or indirect, absolute or conditional, voluntary or involuntary, or disposing of or parting with an asset or an interest in an asset, and includes payment of money, release, lease and…”
Wells Fargo Bank, N.A. Vs. Radecki, 2018 NV 74 (Nev. 2018). “180(1)(b)(2), and NRS 112.190(1). NRS 112.180(1)(b)(1) does not apply, because there was no evidence that the homeowner "[w] as engaged or was about to engage in a business or a transaction for which the remaining assets of the debtor were unreasonably small.”
— Nev. Rev. Stat. § 112.190(2) — 3 cases
Herup v. First Boston Fin., LLC, 162 P.3d 870 (Nev. 2007). “13 NRS 112.190. A fraudulent transfer by an insolvent debtor occurs in two situations: (1) when the debtor makes the transfer without receiving a reasonably equivalent value in exchange for the transfer and the debtor was insolvent at that time or the debtor became insolvent as…”
Bock, LLC v. Steelman (D. Nev. 2020). “180(1) and NRS § 112.190(1). Bock also alleges the same claims 9 against Suzanne and Stephen (the Steelmans’ adult children), arguing that they accepted the 10 transfers to shield those funds and assets from Bock’s post-judgment collection efforts.”
Razaghi (D. Nev. 2025). “NRS 112.190 8 Plaintiff must show the following to be successful under its NRS 112.”
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