“Diminishing” Returns: A Pre-Petition Change of Life Insurance Beneficiary is Not Subject to Avoidance as a Fraudulent Transfer
PBWT
FEBRUARY 25, 2021
” [12] Because the debtor retained ownership of the policy and the related rights – because his rights in the policy were the same both before and after the change – the estate was not “diminished” by the designation of his spouse as beneficiary. at *4-5 (citing 11 U.S.C. §101(54)(D); In re Whitley, 828 F.3d
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