Q: After the trustee takes back the property that was fraudulently tranfered can the transferee become an unsecured creditor?

A: You do not post enough details. Why is this an estate planning question? Why would the recipient of fraudulent transferred property be a creditor? Why exactly was the transfer fraudulent?

I am not sure why there is a trustee. Is this a bankruptcy case? Did the transferee have any reason to know of the fraudulent nature of the transfer? Did the transferee purport to give reasonably equivalent value for the item that was taken back?

Example: a man is being sued for credit card debt. He owns a car and to prevent his creditors from getting it, the man "sells" the car to his son for cash. Because the son is an "insider" and this is not an arms length deal between strangers, the transfer violates the fraudulent conveyance act. The creditor discovers this and goes to court and undoes the transaction.

To the extent the son gave the man money, the son would be a creditor, assuming there are documents to establish some form of liability between the man and his son.

To the extent the son was in on this little scheme of the father's, the son might have an "unclean hands" problem. There is an old maxim in the court that if you come into court asking for relief, you have to have "clean hands" i.e., you can't have engaged in wrongdoing of your own. If you have, the courts will say basically "tough luck" and deny any relief to you because your wrongdoing contributed to the problem.

However, I can change the facts and have the man just re-title the car in the son's name and no money changes hands. The transfer is still fraudulent but the son would not be a creditor.

The fraudulent conveyance statutes are codified at OCGA § 18-2-70 - § 18-2-81. You should review these statutes and any cases arising under them to see if the transferee can get any relief. If this is a bankruptcy matter then you need to consult a bankruptcy attorney.