Pentagon Federal Credit Union v. Poorian

In a case involving fraudulently transferred real property, the appellate court considered whether in a situation where the creditor does not have actual notice of a transfer by debtor, the four-year statute of limitations under the Uniform Fraudulent Transfer Act accrued when the contract of transfer was executed or when the deed was record. The court held that the UFTA cause of action accrued when the deed was recorded. The appellate court also explained that for the purposes of the discovery rule, a UFTA claim does not accrue until the creditor knows or should have known of the fraudulent nature of the transfer, not just the transfer. (ODEN JOHNSON and HYMAN, concurring)