Yan

BACKGROUND

A. The Uniform Voidable Transactions Act (the Act; Civ. Code, § 3439 et seq.) permits defrauded creditors to reach property that a debtor has transferred to a third party with actual fraudulent intent.2 (§ 3439.04, subd. (a)(1) [transfer made by debtor is voidable as to creditor if debtor made transfer “[w]ith actual intent to hinder, delay, or defraud any creditor of the debtor”]; see Kirkeby v. Superior Court (2004) 33 Cal.4th 642, 648; Mejia v. Reed (2003) 31 Cal.4th 657, 663, 664.) Section 3439.08, subdivision (a), provides that an otherwise fraudulent transfer is not voidable “against a person that took in good faith and for a reasonably equivalent value . . . .” An aggrieved creditor may also obtain relief for constructive fraud, without the need to prove the debtor’s actual intent. (§ 3439.05, subd. (a).) The statute provides: “A transfer made or obligation incurred by a debtor is voidable as to a creditor whose claim arose before the transfer was made or the obligation was incurred if the debtor made the transfer or incurred the obligation without receiving a reasonably equivalent value in exchange for the transfer or obligation and the debtor was insolvent at…