August 28, 2017 Value of Collateral Does Not Limit Lender’s Fraudulent Transfer Recovery Ninth Circuit follows the Eleventh with a liberal recovery for an intentionally fraudulent transfer. 9th Circuit , April 12, 2016 Ninth Circuit Makes Glaring Error in Chapter 11 Cramdown Opinion Circuit erroneously cites Section 1325 as governing in chapter 11 cramdown. 9th Circuit ,