Transfer Act, Mass. Gen. Laws. ch. 109A, § 5, which would allow Chambers and Farese to avoid it under Mass. Gen. Laws. ch. 109A, § 8. Despite being raised in Chambers’ and Farese’s counterclaim, the district court never cited to or analyzed Chapter 109A, presumably because of its holding that the validity of the transfer was governed by federal law, not state law. See Mullane, 206 F.Supp.2d at 109-10. However, we agree with Chambers and Farese that state law governs the validity of the transfer and that the district court should have considered whether the transfer was avoidable under Mass. Gen. Laws, ch. 109A, ■ § 8, and/or whether the Mullanes had any defenses under Mass. Gen. Laws. ch. 109A, § 9. See Chase Manhattan Fin. Servs. v. McMillian, 896 F.2d 452, 460 (10th Cir.1990) (<HOLDING>); St. Paul Fire & Marine Ins. Co. v. Vest
holding that state law not admiralty governs the validity of transfers of title holding state law governs disputed ownership of lands recognizing rule that state law governs the substance of claims in bankruptcy proceedings holding that federal law governs remedies available under title ix holding that courts apply substantive admiralty law to claims that sound in admiralty regardless of whether the complaint invokes diversity or admiralty jurisdiction