DZ Bank AG Deutsche Zentral-Genossenschaft Bank v. Meyer, 869 F.3d 839 (9th Cir. 2017) (“DZ Bank”)
In DZ Bank AG Deutsche Zentral-Genossenschaft Bank v. Meyer, 869 F.3d 839 (9th Cir. 2017) (“DZ Bank”), the Ninth Circuit Court of Appeals held that a nondischargeable debt resulting from a fraudulent transfer included the full amount that a bank-creditor would have recovered if the creditor had been able to execute against the debtor’s ownership interests in a closely-held corporation. The Ninth Circuit disagreed with the bankruptcy court and the district court in limiting the nondischargeable debt to the original amount of the collateralized debt ($123,200), versus the full market value of the assets at the time of the fraudulent transfer ($385,000).