The court considered whether payments by check that were delivered to payee shortly before debtor filed its bankruptcy petition were "transferred" when delivered, or when paid by debtor's bank postpetition, for purposes of both avoidance under 11 U.S.C. § 549(a)(1) and the limitations period applicable to such claims in § 549(d). Payee appealed the bankruptcy court's ruling that the transfer occurred on the date debtor's bank actually disbursed funds belonging to debtor, which meant the funds were avoidable as postpetition transfers. The district court affirmed.