Ivey v. First Citizens Bank & Trust Co.
Ivey v. First Citizens Bank & Trust Co. (In re Whitley), 848 F.3d 205 (4th Cir. 2017), the US Court of Appeals for the Fourth Circuit held that a deposit into one’s own bank account is not a “transfer” within the meaning of Section 101(54) and therefore provides no basis for a fraudulent transfer with actual intent to hinder or delay creditors under Section 548(a)(1)(A).
Not binding on Judges in Ninth Circuit, because not a US Court of Appeals for the Ninth Circuit decision; but may be followed by bankruptcy judges, and appellate judges within the Ninth Circuit (includes California), if those judges find the decision to have reasoning that is “persuasive”.