The Supreme Court did not grant certiorari from the 4th Circuit to resolve a spit of decisions, and thus declined to rule on whether a transfer into someone’s own bank account qualifies as a “transfer” on which a fraudulent transfer suit may arise.

Ivey v. First Citizens Bank & Trust Co., 16-1330 (Sup. Court)

In Ivey v. First Citizens Bank & Trust Co. (In re Whitley), 848 F.3d 205 (4th Cir. Jan. 31, 2017), the Fourth Circuit held that a deposit into one’s own bank account is not a “transfer” per Bankruptcy Code Section 101(54) and thus there is no grounds for objection based on a fraudulent transfer with actual intent to hinder or delay creditors under Section 548(a)(1)(A).