Preference

A bankruptcy preference is a pre-filing transfer that may be avoided when it favors an existing creditor under the elements of Section 547.

An avoidable preference is a transfer made before bankruptcy that improves an existing creditor’s position and satisfies the elements of Section 547 of the U.S. Bankruptcy Code. It can include cash payment, transfer of property, granting or perfecting a lien, or another transfer of the debtor’s property interest.

Fraudulent intent is not an element of the federal preference test. An ordinary, legitimate creditor can receive a preference, but the transfer may be protected by a statutory defense.

Key Takeaways

  • Preference law focuses on unequal pre-filing recovery, not moral wrongdoing.
  • The transfer must satisfy every applicable statutory element before defenses are considered.
  • The debt generally must predate the transfer; a substantially contemporaneous exchange is treated differently.
  • Section 547 uses a 90-day pre-filing period and extends the analysis to specified insider transfers during the longer one-year period.
  • Ordinary-course payments, contemporaneous exchange, subsequent new value, and other defenses can reduce or defeat a claim.
  • Avoidance and recovery are separate: Section 550 addresses potential recovery of property or value after a transfer is avoided.

The Section 547 Screening Test

Subject to statutory exceptions, a trustee may seek to avoid a transfer when the required elements are met:

ElementQuestion to ask
Debtor property interestDid value belonging to the debtor leave, become encumbered, or otherwise transfer?
Creditor benefitWas the transfer to or for the benefit of a creditor?
Antecedent debtDid the obligation exist before the transfer was made?
InsolvencyWas the debtor insolvent under the applicable test at the relevant time?
Statutory timingDid the transfer occur within the period Section 547 applies to that creditor and transaction?
Greater recoveryDid the transfer enable the creditor to receive more than it would receive in the hypothetical Chapter 7 comparison required by the statute?

The last element is often overlooked. A fully secured creditor receiving no more than the value of valid collateral may have a different hypothetical liquidation result from a general unsecured creditor expected to receive only a small distribution.

Timing and Insolvency

The Bankruptcy Code generally examines transfers on or within 90 days before the petition date. It also reaches specified transfers to insiders between 90 days and one year before filing. Insider status is defined by the Code and can include certain relatives, controlling persons, partners, affiliates, and related entities depending on the debtor.

Transfer timing is not always the date money visibly moved. Rules for perfection and when a transfer becomes effective against third parties can matter, particularly for liens and security interests.

Section 547 presumes the debtor was insolvent during the 90 days immediately before filing, but the presumption can be rebutted. Outside that presumption, the party asserting insolvency needs appropriate evidence. Book equity alone may not establish the legal insolvency test because asset values, contingent liabilities, and fair valuation can differ from accounting carrying amounts.

Common Preference Defenses

Section 547(c) contains defenses and exceptions. Common analytical categories include:

  • Contemporaneous exchange for new value: The parties intended and substantially completed an exchange rather than paying an old debt.
  • Ordinary course: The debt and payment fit the ordinary course of the parties’ dealings or ordinary business terms under the statutory test.
  • Subsequent new value: After the transfer, the creditor provided qualifying new goods, services, money, or credit that replenished the debtor’s estate.
  • Enabling loan: Specified financing used to acquire property can be protected when the security interest is perfected within the statutory conditions.
  • Statutory lien and other exceptions: The Code protects specified transfers, liens, support payments, and transactions when their requirements are met.

Defenses are fact-intensive. Payment timing, collection pressure, changed terms, unusual payment methods, returned goods, credit memos, later invoices, and lien-perfection records can all affect the analysis.

Worked Example: Trade-Creditor Payment

Assume a distributor owes a supplier $120,000 on overdue invoices. Forty-five days before filing Chapter 7, the distributor pays $90,000 after the supplier threatens to place the account on credit hold. The supplier then ships $30,000 of additional goods on credit, which remain unpaid at filing.

Assume general unsecured creditors are currently estimated to recover 15% in the hypothetical liquidation. If no payment had been made, a $120,000 unsecured claim would have an estimated $18,000 distribution at that rate. The $90,000 transfer therefore requires preference review because it may have improved the supplier’s recovery.

That does not establish that $90,000 must be returned. The trustee must establish the statutory elements and conduct required due diligence, including known or reasonably knowable defenses. The supplier may assert ordinary-course treatment and subsequent new value for the later shipment. The parties would also verify invoice dates, payment history, collection communications, returned goods, credits, and whether any claim was secured.

The example is a screening exercise, not a legal exposure calculation. The allowable claim, defenses, settlement economics, and recoverable amount depend on evidence and law.

Preference Versus Fraudulent Transfer

FeaturePreferenceFraudulent Transfer
Typical recipientExisting creditor or beneficiary of a creditor paymentAny transferee or beneficiary covered by the applicable rule
Core concernCreditor received more than the statutory Chapter 7 comparison permitsDebtor acted with prohibited intent or received insufficient value under specified financial conditions
Antecedent debtCentral to the federal preference testNot required for every fraudulent-transfer theory
IntentFraudulent intent is not requiredActual-intent theory requires intent; constructive theory does not
DefensesOrdinary course, contemporaneous exchange, new value, and other statutory protectionsValue, good faith, and other protections depend on the governing provision

A transaction can require analysis under more than one avoidance theory, but the elements and defenses should not be blended.

Why Preference Risk Matters in Finance

For a trade creditor, receiving late payment does not always end the credit risk. A later preference demand can create a contingent receivable reversal, legal cost, and financial-statement reserve question. For a lender, delayed lien perfection or unusual debt paydown can affect recoverability. For a distressed-debt buyer, potential avoidance recoveries can increase estate value, but they remain uncertain litigation assets.

Preference analysis should distinguish gross asserted amount from expected net recovery:

Expected recovery = asserted transfer amount x probability of success x collectible percentage - legal and collection costs

Each input is uncertain. Settlement timing and the recipient’s financial capacity can matter as much as the pleaded amount.

Common Mistakes

  • Assuming malicious intent or an insider relationship is required.
  • Treating every payment within 90 days as automatically avoidable.
  • Ignoring the hypothetical Chapter 7 comparison.
  • Measuring insolvency only from book equity.
  • Ignoring ordinary-course history, subsequent new value, or contemporaneous exchange.
  • Using payment date alone when perfection rules determine transfer timing.
  • Recording a demand letter as a collected estate asset.

Preference law is technical and fact-specific. This article provides financial education, not legal, tax, credit, litigation, claim-defense, or transaction advice.

Official Sources

FAQs

Does a preference require fraud or bad intent?

No. The federal preference test focuses on the statutory transfer, debt, insolvency, timing, and hypothetical recovery elements. Intent can explain the facts, but fraudulent intent is not required.

Is every payment made within 90 days of bankruptcy avoidable?

No. Every statutory element must be met, and defenses or exceptions can apply. Ordinary-course payments, contemporaneous exchange, subsequent new value, secured status, and transaction timing can change the result.

Why can a supplier face a preference claim after delivering real goods?

The claim concerns whether a payment on old debt improved the supplier’s position shortly before bankruptcy. Goods or credit supplied after the payment may support a new-value defense, while ordinary-course history can support another defense.
Browse Credit and Lending