A foreclosure sale of real estate held in accordance with applicable state law and without an element of improper collusion that could have the effect of “chilling” the purchase price at the sale. The U.S. Supreme Court’s BFP decision held that such a sale cannot be a fraudulent transfer no matter how low the purchaser bids at the sale. The court in the BFP case stated that its holding extended only to real estate foreclosure sales.
See also BFP Case, Constructively Fraudulent Transfer, Durrett Case, Reasonably Equivalent Value.