n7 We are unpersuaded by petitioner's argument that the 1984
amendments to the Bankruptcy Code codified the Durrett Rule. Those amendments expanded the
definition of "transfer" to include "foreclosure of the debtor's equity of
redemption," 11 U.S.C. 101(54) (1988 ed., Supp. IV), and added the words
"voluntarily or involuntarily" as modifiers of the term "transfer" in
548(a). The first of these provisions establishes that foreclosure sales fall
within the general definition of "transfers" that may be avoided under several
statutory provisions, including (but not limited to) 548. See 522(h)
(transfers of exempt property), 544 (transfers voidable under state law), 547
(preferential transfers), 549 (postpetition transfers). The second of them
establishes that a transfer may be avoided as fraudulent even if it was against the
debtor's will. See In re Madrid, 725 F.2d 1197, 1199 (CA9 1984) (pre-amendment decision
holding that a foreclosure sale is not a "transfer" under 548). Neither of
these consequences has any bearing upon the meaning of "reasonably equivalent
value" in the context of a foreclosure sale.
Nor does our reading render these amendments "superfluous," as the dissent
contends, post, at 8. Prior to 1984, it was at least open to question whether 548
could be used to invalidate even a collusive foreclosure sale, see Madrid, 725 F.2d, at
1204 (Farris, J., concurring). It is no superfluity for Congress to clarify what had been
at best unclear, which is what it did here by making the provision apply to involuntary as
well as voluntary transfers and by including foreclosures within the definition of
"transfer." See infra, at 14-15.