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U.S. Supreme CourtBFP v. Resolution Trust Corp., 511 U.S. 531, 114 S. Ct. 1757, 128 L. Ed. 2d 556, 25 Bankr.Ct. Dec. (CRR) 1051, 30 Collier Bankr. Cas. 2d (MB) 345, Bankr. L. Rep. (CCH) 75885(1994) (The price obtained at a foreclosure sale of real property under state law is reasonableequivalent value.)Preference Actions1. DefinitionSection 547 of the Bankruptcy Code permits a trustee to avoid any transferof an interest of the Debtor in property, made to a creditor on account if anantecedent debt within 90 days prior to the filing of the bankruptcy petition (oneyear if the transferee is an insider) while the Debtor is insolvent, which enables tocreditor to receive more than the creditor would have received in a Chapter 7 casehad the payment not been made. The rationale for this provision is to prevent therush to the courthouse by the creditors and to create a level playing feel amongcreditors.2. DefensesThere are three primary defenses to a preference action: contemporaneousexchange, new value and ordinary course.(a) Contemporaneous exchangeIf the transfer of property or payment is made simultaneously with thegiving of new value, then the transfer is protected. 2 For example, if goods areshipped and paid COD, then there is no preference. This holds even if thepayment is made by check, as long as the check is cashed within a reasonabletime.(b) New valueTo the extent that a creditor extends new value after a preference, then theamount of the new value is protected. 3 For example, on Monday, the debtor pays2 11 U.S.C. § 547(c)(1).3 11 U.S.C. § 547(c)(4).