Cates, In re--Walters v. Cates

Ruling: 
Section 547(e)(3) did not change the deemed transfer date even though the deed of trust waslater recorded at a time when a family trust held record title to the property, because the debtorhad rights in the property on the date she granted the deed of trust. (B.A.P. 10th Cir.)
Issue: 
Preferences; Perfection and Effectiveness; Acquisition of Rights by Debtor.
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Consumer case opionion summary, case decided on March 04,2013, LexisNexis #1018-020