In what circumstances will a court set aside a fraudulent conveyance of an insurance policy?

In our view the trial court erroneously construed Bryson v. Manhart, supra, to limit fraudulent conveyances of insurance policies to those situations in which the debtor changes the beneficiary of the policy from his estate to a third person. This appears to be the most conventional fact pattern, but there is no reason to make it a prerequisite. In actions to set aside a fraudulent conveyance, the relevant inquiry is whether the debtor has put some asset beyond the reach of creditors which would have been available to them but for the conveyance.