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122 360Networks (USA) Inc. v. AAF-McQuay, Inc. (In re 360Networks (USA) Inc.), 327 B.R. 187, 193 (Bankr. S.D.N.Y. 2005). 6. Limitations on Avoidance Section 546 of the Bankruptcy Code sets forth certain limitations on the ability of the trustee or debtor-in-possession to utilize its avoidance powers. According to Section 546(a) of the Bankruptcy Code, avoidance actions and actions commenced under certain other Sections of the Bankruptcy Code must be commenced within two years after the entry of the order for relief unless the case is closed before that time. However, if a trustee is appointed, the trustee must commence avoidance actions within one year of appointment of the initial trustee (as long as the two- year period had not expired before the appointment) unless the case is closed before that time. 11 U.S.C. ยง 546(a)(1). Certain State laws allow perfection within a set period of time to relate back to the date on which an interest was created, which allows the holder of the security interest to defeat the rights of an intervening creditor. Section 546(b)(1) provides that the trustee's strong arm powers, power to avoid statutory liens, and power to avoid certain postpetition transactions may not interfere with this right where it extends into the postpetition time period. This Section also permits a secured creditor to take actions postpetition as necessary to continue or maintain a prepetition security interest. Id. Thus, for example, secured creditors are permitted to file UCC-3 continuation statements after the petition date. Additionally, the trustee's powers under various of the avoidance actions are subject to a seller's right to demand the return of goods sold to the debtor in the ordinary course of the seller's business if the debtor received such goods while insolvent, within the forty-five days prior to the petition date. 71 11 U.S.C. 71 The test for insolvency in Section 546 is the "modified" balance sheet test discussed above in footnote 57. This right of reclamation is derived from Section 2-702 of the UCC, which permits a seller to reclaim goods that a buyer has received on credit while insolvent if the seller discovers the buyer was insolvent when the seller provided the goods.