Section 3439.05 - Transfer made or obligation incurred fraudulent as to creditor whose claim arose before transfer(a) 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 that time or the debtor became insolvent as a result of the transfer or obligation.(b) A creditor making a claim for relief under subdivision (a) has the burden of proving the elements of the claim for relief by a preponderance of the evidence.Amended by Stats 2015 ch 44 (SB 161),s 7, eff. 1/1/2016.