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Genuine Issues of Material Fact Remained Concerning Whether the Transfer of the Security Interest Is Excepted from Avoidance Under §547(c)(1).

Idaho, September 18, 2017 – Debtor purchased a vehicle on a loan. The loan was secured by a security interest in the vehicle. Subsequently, the Debtors decided to refinance the original purchase-money loan on the vehicle using the proceeds of a new loan they obtained from Defendant America First. The Defendant had a security interest in the vehicle. After the Debtor filed for bankruptcy, the Trustee brought an adversary proceeding to avoid the Defendant’s first’s lien on the vehicle as a preference under § 547(b), and to recover the vehicle, or its value, under § 550(a).The Court held that the Debtors’ transfer of the security interest to the new lienholder was on account of an anteced


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