§ 546

Bankruptcy court did not err in dismissing the complaint as it found that plaintiff had nottimely perfected its lien under California law nor had it preserved its lien by filing a timelynotice. (B.A.P. 9th Cir.)

Summary judgment denied due to failure to show that transfers were for less than equivalentvalue. (Bankr. N.D. Ohio)

Good cause existed to allow a liquidating trustee to proceed on his motion for leave to amendcomplaint in avoidance proceeding after the scheduling order deadline. (Bankr. S.D. Tex.)

Safe harbor provision did not bar trustee’s avoidance proceeding as neither party to thetransfer was a financial institution. (Bankr. E.D. Mich.)[1]-The safe harbor provision of 11 U.S.C. § 546(e) did not bar plaintiff's trustee's adversary proceedingseeking to avoid and recover pre-petition transfers from the debtor to defendants as fraudulent becausethe transfer the trustee sought to avoid was a 2005 transfer from the debtor to defendants, the 2005transaction fell outside of the § 546(e) safe harbor because neither the transferor (the debtor) or thetransferee (defendants) were a financial institution or other covered entity, defendants failed to establishthat the 2005 transaction was "for the benefit" of a financial institution, and defendants failed to provethat the debtor was deemed to be a "financial institution" under 11 U.S.C. § 101(22)(A).Greektown Holdings, LLC, In re--Buchwald Capital Advisors, LLC v. Papas, 2020 Bankr. LEXIS 2938 (Bankr. E.D.Mich. October 19, 2020) (Oxholm, B.J.).