Revised Code of Washington
Wash. Rev. Code § 19.40.905 (2026)
✓ current as of May 2026
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(1) Chapter 57, Laws of 2017 applies to a transfer made or obligation incurred on or after July 23, 2017.
(2) Chapter 57, Laws of 2017 does not apply to a transfer made or obligation incurred before July 23, 2017.
(3) Chapter 57, Laws of 2017 does not apply to a right of action that has accrued before July 23, 2017.
(4) For the purposes of this section, a transfer is made and an obligation is incurred at the time provided in RCW 19.40.061.
[ 2017 c 57 s 14.]
Notes of Decisions
Cited in 8
cases (5 in the last 5 years), 2018–2025 · leading case: Calvert v. Erdman (In re Nw. Territorial Mint, LLC), 591 B.R. 852 (Bankr. W.D. Wash. 2018).
Calvert v. Erdman (In re Nw. Territorial Mint, LLC), 591 B.R. 852 (Bankr. W.D. Wash. 2018). “Per RCW § 19.40.905 (2017), the UVTA does not apply to transfers made or obligation incurred prior to July 23, 2017.”
Northgate Ventures Llc v. Geoffrey H. Garrett Pllc, 450 P.3d 1210 (Wash. Ct. App. 2019). “RCW 19.40.905. 14 No. 78495-1-1/15 (i) Was engaged or was about to engage in a business or a transaction for which the remaining assets of the debtor were unreasonably small in relation to the business or transaction; or (ii) Intended to incur, or believed or reasonably should…”
BGH Holdings, LLC v. DL Evans Bank (W.D. Wash. 2023). “RCW § 19.40.905(2). Therefore, for the purposes of this Order, 22 we cite to former chapter 19.”
John Shubeck, Shelly Williams, V Catherine Shubeck (Wash. Ct. App. 2021). “40, formerly known as UFTA, is now known as the Uniform Voidable Transactions Act.”
United States v. Weathers (W.D. Wash. 2020). “But even if the prior encumbrances were 2 relevant to Tom’s transfer, the Government asserts that the nature of the encumbrances is 3 a contested issue of material fact.”
United States v. Weathers (W.D. Wash. 2021). “The 2 United States counters that because the Weathers did not pay all of their tax liability 3 when they filed their 1996 tax return, they were presumed insolvent under RCW 4 19.”
United States v. Gould (W.D. Wash. 2024). “RCW 19.40.905; see also United States v. Weathers, 532 F.”
Kenneth Wren, et ux. v. Stanford & Sons, LLC (Wash. Ct. App. 2025). “RCW 19.40.905. 22 An “insider” includes various individuals in certain relationships with the debtor, depending if the debtor is an individual, a corporation, or a partnership.”
— Wash. Rev. Code § 19.40.905(2) — 2 cases
BGH Holdings, LLC v. DL Evans Bank (W.D. Wash. 2023). “RCW § 19.40.905(2). Therefore, for the purposes of this Order, 22 we cite to former chapter 19.”
John Shubeck, Shelly Williams, V Catherine Shubeck (Wash. Ct. App. 2021). “40, formerly known as UFTA, is now known as the Uniform Voidable Transactions Act.”
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