Wash. Rev. Code » Title 19 · Chapter 19.40
Revised Code of Washington

Wash. Rev. Code § 19.40.091 (2026)

Extinguishment of claim for relief

✓ current as of May 2026
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A claim for relief with respect to a transfer or obligation under this chapter is extinguished unless action is brought:
(1) Under RCW 19.40.041(1)(a), not later than four years after the transfer was made or the obligation was incurred or, if later, not later than one year after the transfer or obligation was or could reasonably have been discovered by the claimant;
(2) Under RCW 19.40.041(1)(b) or 19.40.051(1), not later than four years after the transfer was made or the obligation was incurred; or
(3) Under RCW 19.40.051(2), not later than one year after the transfer was made.
[ 2017 c 57 s 9; 1987 c 444 s 9.]

Notes:

Effective date—1987 c 444: See note following RCW 19.40.011.
Notes of Decisions
Cited in 20 cases (4 in the last 5 years), 1994–2026 · leading case: Freitag v. McGhie, 947 P.2d 1186 (Wash. 1997).
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Freitag v. McGhie, 947 P.2d 1186 (Wash. 1997). · cites it 19× “RCW 19.40.091 plainly provides any action to set aside a fraudulent transfer is extinguished one year after the transfer was, or could have been, discovered.”
Freitag v. McGhie, 133 Wash. 2d 816 (Wash. 1997). · cites it 19× “RCW 19.40.091 plainly provides any action to set aside a fraudulent transfer is extinguished one year after the transfer was, or could have been, discovered.”
Sorenson v. Pyeatt, 146 P.3d 1172 (Wash. 2006). · cites it 2× “[17] The trial court dismissed this issue concluding that the Lenders' claim under the Uniform Fraudulent Transfer Act was time-barred under RCW 19.40.091(a). RCW 19.40.091(a) provides, in essence, that a creditor's fraudulent transfer claim be brought within four years of the…”
McMaster v. Farmer, 886 P.2d 240 (Wash. Ct. App. 1994). · cites it 7× “RCW 19.40.091 provides: *467 A cause of action with respect to a fraudulent transfer or obligation under this chapter is extinguished unless action is brought: (a) Under RCW 19.”
Angelo v. Angelo, 175 P.3d 1096 (Wash. Ct. App. 2008). “RCW 19.40.091; see Freitag v. McGhie, 133 Wn.”
Calvert v. Erdman (In re Nw. Territorial Mint, LLC), 591 B.R. 852 (Bankr. W.D. Wash. 2018). · cites it 2× “RCW § 19.40.091(a) and (b). As of April 2012 and through the Petition Date, numerous creditors of the Mint had viable claims under the WUFTA, as evidenced by the list of Accounts Payable.”
Finn v. All. Bank, 838 N.W.2d 585 (Minn. Ct. App. 2013). “9, § 2293 (2006); Wash. Rev.Code Ann. § 19.40.091 (West 2013); W.”
Summit Sec., Inc. v. Sandifur (In re Metro. Mortg. & Sec. Co.), 344 B.R. 138 (Bankr. E.D. Wash. 2006). “2 Causes of action under these two statutory provisions are limited by RCW 19.40.091(b) which states that any cause of action based upon RCW 19.”
Calvert v. Radford (In re Consol. Meridian Funds), 487 B.R. 263 (Bankr. W.D. Wash. 2013). “RCW 19.40.091. 6 Section 548(a)(1) gives the Trustee an avenue for recovery of an intentionally fraudulent transfer [§ 548(a)(1)(A) ] and a constructively fraudulent transfer [§ 548(a)(1)(B) ].”
Kriegman v. Schultz (In re LLS Am., LLC), 520 B.R. 841 (E.D. Wash. 2014). “041(a)(1), RCW 19.40.091(a) and the “strong arm powers” that 11 U.”
Angelo v. Angelo, 175 P.3d 1096 (Wash. Ct. App. 2008). “RCW 19.40.091; See Freitag v. McGhie, 133 Wash.”
A & W Farms v. Cook, 277 P.3d 67 (Wash. Ct. App. 2012). “The first fraudulent transfer occurred in April 1999. The 2002 filing of the fraudulent transfer complaint was well within four years of the real property transfers.”
Show all 20 citing cases →
— Wash. Rev. Code § 19.40.091(1) — 1 case
In The Receivership Of Eunia Lee (Wash. Ct. App. 2026).
— Wash. Rev. Code § 19.40.091(a) — 10 cases
Freitag v. McGhie, 947 P.2d 1186 (Wash. 1997). “RCW 19.40.091 plainly provides any action to set aside a fraudulent transfer is extinguished one year after the transfer was, or could have been, discovered.”
Freitag v. McGhie, 133 Wash. 2d 816 (Wash. 1997). “RCW 19.40.091 plainly provides any action to set aside a fraudulent transfer is extinguished one year after the transfer was, or could have been, discovered.”
Sorenson v. Pyeatt, 146 P.3d 1172 (Wash. 2006). “[17] The trial court dismissed this issue concluding that the Lenders' claim under the Uniform Fraudulent Transfer Act was time-barred under RCW 19.40.091(a). RCW 19.40.091(a) provides, in essence, that a creditor's fraudulent transfer claim be brought within four years of the…”
McMaster v. Farmer, 886 P.2d 240 (Wash. Ct. App. 1994). “RCW 19.40.091 provides: *467 A cause of action with respect to a fraudulent transfer or obligation under this chapter is extinguished unless action is brought: (a) Under RCW 19.”
Calvert v. Erdman (In re Nw. Territorial Mint, LLC), 591 B.R. 852 (Bankr. W.D. Wash. 2018). “RCW § 19.40.091(a) and (b). As of April 2012 and through the Petition Date, numerous creditors of the Mint had viable claims under the WUFTA, as evidenced by the list of Accounts Payable.”
— Wash. Rev. Code § 19.40.091(b) — 3 cases
Summit Sec., Inc. v. Sandifur (In re Metro. Mortg. & Sec. Co.), 344 B.R. 138 (Bankr. E.D. Wash. 2006). “2 Causes of action under these two statutory provisions are limited by RCW 19.40.091(b) which states that any cause of action based upon RCW 19.”
McMaster v. Farmer, 886 P.2d 240 (Wash. Ct. App. 1994). “RCW 19.40.091 provides: *467 A cause of action with respect to a fraudulent transfer or obligation under this chapter is extinguished unless action is brought: (a) Under RCW 19.”
Summit Sec., Inc. v. Sandifur (In re Metro. Mortg. & Sec. Co.), 343 B.R. 247 (Bankr. E.D. Wash. 2006).
— Wash. Rev. Code § 19.40.091(c) — 1 case
Dbm Consulting Engineers, Inc. v. Joseph D. Sanders (Wash. Ct. App. 2015).
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