In Federal Deposit Ins. Co. v. Porco (75 NY2d 840, 842, 552 N.E.2d 158, 552 N.Y.S.2d 910 ), the Court of Appeals interpreted Debtor & Creditor Law §§ 278 and 279.
The Court held, "Those sections did not, either explicitly or implicitly, create a creditor's remedy for money damages against parties who, like defendants here, were neither transferees of the assets nor beneficiaries of the conveyance."
The Court of Appeals also rejected the argument that such a remedy was available under Debtor & Creditor Law § 273, holding, "the statute still cannot fairly be read as creating a remedy against nontransferees who, like defendants here, are not alleged to have dominion or control over those assets or to have benefited in any way from the conveyance." Id.