South Dakota Code § 44-3-2

Marshaling securities among lien holders--Several things within the same class and subject to same number of liens--Property to which resort may be had
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When several things are within one of the classes described by §
44-3-1
and subject to the same number of liens, resort must be had:
(1) To the things which had not been transferred since the prior lien was created;
(2) To the things which have been so transferred without a valuable consideration; and
(3) To the things which have been so transferred for a valuable consideration.

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