NRS
112.220 Avoidance of transfer or obligation: Protection of good faith
transferee or obligee; recovery of judgment for value of asset transferred;
certain transfers not voidable.
1. A transfer or obligation is not voidable
under paragraph (a) of subsection 1 of NRS
112.180 against a person who took in good faith and for a reasonably
equivalent value or against any subsequent transferee or obligee.
2. Except as otherwise provided in this
section, to the extent a transfer is voidable in an action by a creditor under
paragraph (a) of subsection 1 of NRS 112.210,
the creditor may recover judgment for the value of the asset transferred, as
adjusted under subsection 3 of this section, or the amount necessary to satisfy
the creditor’s claim, whichever is less. The judgment may be entered against:
(a) The first transferee of the asset or the
person for whose benefit the transfer was made; or
(b) Any subsequent transferee other than a
transferee who took in good faith for value or from any subsequent transferee.
3. If the judgment under subsection 2 is
based upon the value of the asset transferred, the judgment must 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.
4. Notwithstanding voidability of a
transfer or an obligation under this chapter, a transferee or obligee who took
in good faith is entitled, to the extent of the value given the debtor for the
transfer or obligation, to:
(a) A lien on or a right to retain any interest
in the asset transferred;
(b) Enforcement of any obligation incurred; or
(c) A reduction in the amount of the liability on
the judgment.
5. A transfer is not voidable under
paragraph (b) of subsection 1 of NRS 112.180
or NRS 112.190 if the transfer results
from:
(a) Termination of a lease upon default by the
debtor when the termination is pursuant to the lease and applicable law; or
(b) Enforcement of a security interest in
compliance with NRS 104.9101 to 104.9709, inclusive.
6. A transfer is not voidable under
subsection 2 of NRS 112.190:
(a) 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;
(b) If made in the ordinary course of business or
financial affairs of the debtor and the insider; or
(c) 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.
(Added to NRS by 1987,
12; A 1999,
389)
Notes of Decisions
Herup v. First Boston Fin., LLC, 162 P.3d 870 (Nev. 2007).
· cites it 6× “NRS 112.220(1) provides a complete defense for an action for avoidance under NRS 112.”
Gingold v. Itronics, Inc. (D. Nev. 2025).
· cites it 4× “19 20 21 17Under NRS § 112.220(1), “[a] transfer or obligation is not voidable under [] NRS 22 112.”
Morgan Stanley High Yield Sec. Inc v. Jecklin (D. Nev. 2020).
· cites it 3× “[a]ny other relief the circumstances may require.” Nev. Rev. Stat. § 112.210 . 1 Plaintiffs argue the Court’s order and judgment explicitly awarded Plaintiffs attorneys’ 2 fees, and the award was authorized by NRS § 112.”
The Cadle Co. Vs. Woods & Erickson c/w 63790, 2015 NV 15 (Nev. 2015).
· cites it 4× “210; NRS 112.220(2). Nevada law does not create a legal cause of action for damages in excess of the value of the property to be recovered.”
Moh Mgmt., LLC v. Michelangelo Leasing, Inc. (Nev. 2019).
· cites it 2× “Even if the transfer constitutes an actual fraudulent transfer under the Uniform Fraudulent Transfer Act, the transfer is voidable if it falls under the good faith defense described in NRS 112.”
Moh Mgmt., LLC v. Michelangelo Leasing, Inc. (Nev. 2019).
· cites it 2× “Even if the transfer constitutes an actual fraudulent transfer under the Uniform Fraudulent Transfer Act, the transfer is voidable if it falls under the good faith defense described in NRS 112.”
The Cadle Co. Vs. Woods & Erickson c/w 63790, 2015 NV 15 (Nev. 2015).
· cites it 2× “210; NRS 112.220(2). Nevada law does not create a legal cause of action for damages in excess of the value of the property to be recovered.”
The Cadle Co. Vs. Woods & Erickson c/w 63790, 2015 NV 15 (Nev. 2015).
· cites it 2× “210; NRS 112.220(2). Nevada law does not create a legal cause of action for damages in excess of the value of the property to be recovered.”
Tahican, LLC v. Eighth Jud. Dist. Ct., 140 Nev. Adv. Op. No. 2 (Nev. 2024).
“NRS 112.220(1). Thus, if a lis pendens is not available to creditors in fraudulent transfer actions, the property could be transferred to a good faith transferee during the litigation, which would "cut ofT the creditor's rights, and the court's power, to undo the prior transfer.”
GW Grundbesitz AG v. Gunn (D. Nev. 2023).
“§ 112.220(1). The essence of Gunn’s good-faith defense is that she and Wild entered 23 into the RSA “while ending their relationship” and that under the agreement, Wild was to pay 24 her the purchase price of the Dossenheim properties, along with multi-million-dollar gifts 25…”
— Nev. Rev. Stat. § 112.220(1) — 6 cases
Moh Mgmt., LLC v. Michelangelo Leasing, Inc. (Nev. 2019).
“Even if the transfer constitutes an actual fraudulent transfer under the Uniform Fraudulent Transfer Act, the transfer is voidable if it falls under the good faith defense described in NRS 112.”
Moh Mgmt., LLC v. Michelangelo Leasing, Inc. (Nev. 2019).
“Even if the transfer constitutes an actual fraudulent transfer under the Uniform Fraudulent Transfer Act, the transfer is voidable if it falls under the good faith defense described in NRS 112.”
Gingold v. Itronics, Inc. (D. Nev. 2025).
“19 20 21 17Under NRS § 112.220(1), “[a] transfer or obligation is not voidable under [] NRS 22 112.”
Tahican, LLC v. Eighth Jud. Dist. Ct., 140 Nev. Adv. Op. No. 2 (Nev. 2024).
“NRS 112.220(1). Thus, if a lis pendens is not available to creditors in fraudulent transfer actions, the property could be transferred to a good faith transferee during the litigation, which would "cut ofT the creditor's rights, and the court's power, to undo the prior transfer.”
— Nev. Rev. Stat. § 112.220(2) — 4 cases
Gingold v. Itronics, Inc. (D. Nev. 2025).
“19 20 21 17Under NRS § 112.220(1), “[a] transfer or obligation is not voidable under [] NRS 22 112.”
— Nev. Rev. Stat. § 112.220(2)(a) — 1 case
Morgan Stanley High Yield Sec. Inc v. Jecklin (D. Nev. 2020).
“[a]ny other relief the circumstances may require.” Nev. Rev. Stat. § 112.210 . 1 Plaintiffs argue the Court’s order and judgment explicitly awarded Plaintiffs attorneys’ 2 fees, and the award was authorized by NRS § 112.”
— Nev. Rev. Stat. § 112.220(3) — 1 case
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