2nd Circuit

2nd Circuit May 5, 2022

An Initial ‘Recipient’ of a Fraudulent Transfer Isn’t Always Liable Under § 550(a)(1)

The Second Circuit says that an initial ‘recipient’ isn’t automatically an initial ‘transferee’ liable for an avoidable transfer under Section 550(a)(1).

Another District Judge Rules that Tax Foreclosures Can Be Fraudulent Transfers

The circuits are split on whether the Supreme Court’s BFP opinion can be extended to bar fraudulent transfer attacks on in rem real estate tax foreclosures.

On Student Loan Discharge, District Judge Requires Responses to Unasserted Defenses

New York district judge requires a student loan debtor to prove the reasonableness of living expenses when the lender never objected.

Texas Judge Disagrees with Second Circuit on Sanctions for Violating Rule 3002.1

Bankruptcy Judge Eduardo Rodriguez explained why the Second Circuit was wrong in ruling that violators of Rule 3002.1 are only liable for compensatory damages.