Answer: yes, according to a recent Southern District ruling, involving the Salander-O'Reilly bankruptcy, discussed here.
The holding is that "a creditor could obtain a security interest in a consigned item senior to that of a consigneee who does not file a [UCC] financing statement": "The law operates as follows: a consignor delivers goods to a [gallery], but does not file a financing statement, and thus the consignor's security interest is unperfected. The [gallery] then grants a security interest in the consigned item to a creditor, who perfects [the security interest] by filing a proper financing statement." In those circumstances, "the creditor's rights are senior to" the consignor's unperfected security interest.
The idea behind the rule is "to protect general creditors of the [gallery] from claims of consignors that have undisclosed consignment arrangements with the [gallery] that create secret liens on the inventory. To a general creditor of [Salander-O'Reilly's] such as the Bank, which could base the amount of a loan on the inventory possessed by a consignee, consigned property appears to be property wholly owned by the consignee unless the consignor files a UCC-1 financing statement, which notifies creditors of the status of a consigned item."
UPDATE: I should have mentioned that this doesn't apply to consignments by artists (at least in New York), which are given special statutory protection.
