Commerce Lesson #2

Who's Got the Note?

Instruments change hands. Understanding who can actually enforce one against you — and what defenses exist — is essential for navigating commercial disputes.

A negotiable instrument can be sold, transferred, and traded. When someone claims you owe them money, the first question isn't "do I owe?" — it's "can YOU enforce?"

Who Can Enforce an Instrument?

Person Entitled to Enforce
UCC § 3-301
"Person entitled to enforce" means: (1) The holder of the instrument; (2) A nonholder in possession who has the rights of a holder; (3) A person not in possession who is entitled to enforce under Section 3-309 or 3-418(d).

The most common enforcer is the "holder" — but even non-holders can sometimes enforce if they acquired the rights properly.

The Troubling Detail

UCC 3-301 continues: "A person may be a person entitled to enforce the instrument even though the person is not the owner of the instrument or is in wrongful possession of the instrument."

Translation: Someone can potentially enforce an instrument even if they shouldn't have it. The system prioritizes negotiability over ownership rights.

What Makes Someone a "Holder"?

Holder
UCC § 1-201(b)(21)
"'Holder' means the person in possession of a negotiable instrument that is payable either to bearer or to an identified person that is the person in possession."

Two requirements to be a holder:

1. Possession

You physically have the instrument (or control of electronic equivalent). No possession? Not a holder.

2. Payable to You

Either it names you specifically, or it's bearer paper (payable to whoever has it). Wrong name? Not a holder.

Holder in Due Course: The Super-Holder

A "holder in due course" (HDC) is a special category with enhanced enforcement rights:

Holder in Due Course
UCC § 3-302(a)
"Holder in due course" means the holder of an instrument if: (1) the instrument does not bear apparent evidence of forgery or alteration; (2) the holder took for value; (3) the holder took in good faith; (4) the holder took without notice of problems.

Why HDC Status Matters

A holder in due course takes the instrument free of most defenses. If a bank becomes an HDC of your promissory note, many arguments you might raise become legally irrelevant to enforcement.

Defense Type vs. Ordinary Holder vs. HDC
Personal Defenses
Failure of consideration, fraud in inducement, breach of warranty
Available NOT Available
Real Defenses
Forgery, minority, fraud in factum, illegality
Available Available
The Strategic Implication

This is why banks and servicers structure transactions to achieve HDC status — it cuts off most defenses. When challenging a mortgage, you may need to attack whether they truly qualify as HDC: Did they give value? Did they have notice of problems? Can they prove it?

How Instruments Transfer: Negotiation

Negotiation
UCC § 3-201(a)
"'Negotiation' means a transfer of possession, whether voluntary or involuntary, of an instrument by a person other than the issuer to a person who thereby becomes its holder."
Step 1
Issue

First delivery by maker or drawer — the instrument comes to life.

Step 2
Holder

Person in possession with right to payment.

Step 3
Negotiation

Transfer making the recipient a holder (may require endorsement).

Step 4
Enforcement

Holder demands payment from obligor.

For bearer paper, mere transfer of possession negotiates the instrument. For order paper (made out to a specific person), endorsement is required.

Types of Endorsement

Endorsement is how order paper gets negotiated. The type of endorsement affects who can enforce:

Blank Endorsement

Does NOT state the payee — automatically makes the instrument payable to bearer. Anyone who possesses it can enforce.

/s/ John Smith

Effect: Whoever holds it can cash it or transfer it.

Special Endorsement

States the specific payee — only that person can enforce or further negotiate.

Pay to the order of Jane Doe
/s/ John Smith

Effect: Only Jane Doe can now enforce or transfer.

Qualified Endorsement ("Without Recourse")

Limits the endorser's liability if the instrument is dishonored.

Without recourse
Pay to the order of Jane Doe
/s/ John Smith

Effect: John Smith is not liable if the maker doesn't pay.

Restrictive Endorsement

Limits what can be done with the instrument.

For deposit only to Account #12345
/s/ John Smith

Effect: Must be deposited to specified account.

Lost, Destroyed, or Stolen Instruments

What if the original instrument can't be produced?

Enforcement Without the Instrument
UCC § 3-309
"A person not in possession of an instrument is entitled to enforce the instrument if: (1) the person was entitled to enforce when loss occurred; (2) the loss was not from transfer or lawful seizure; and (3) the person cannot reasonably obtain possession."

This creates a pathway for enforcing instruments even without the original. But it also creates opportunities for challenge:

Demanding the Original

If you request the original "wet-ink" promissory note and the claiming party cannot produce it, you may be able to:

  • Challenge their standing to enforce
  • Require them to meet the burden of UCC 3-309
  • Raise questions about chain of title
  • Force them to prove they qualify to enforce without it

The Chain of Title Problem

In modern mortgage securitization, notes are often transferred multiple times:

  1. Originator creates loan, takes your note
  2. Sells note to aggregator
  3. Aggregator pools notes into securities
  4. Securities sold to investors
  5. Servicer handles payments and enforcement

Each transfer should be properly endorsed. But in practice, many transfers happened without proper endorsement — especially during the 2000s mortgage boom.

Common Chain of Title Defects

Missing Endorsements

Gaps in the endorsement chain from originator to current holder.

MERS Issues

Electronic registration system problems and confusion about who holds what.

Robo-Signing

Fraudulent execution of documents by unqualified personnel.

Backdated Assignments

Documents created after the fact to paper over transfer problems.

These defects don't automatically void your obligation, but they can be powerful challenges to the claiming party's standing to enforce.

Standing Challenges

Before addressing the merits of any claim, you can challenge whether the plaintiff has standing to bring it:

The Questions to Ask
  • Are you the holder of the original note?
  • Can you produce the original wet-ink instrument?
  • Show the complete chain of endorsements
  • Prove you gave value for the note (UCC 3-302)
  • Demonstrate you took in good faith without notice of defects

If the claiming party cannot prove they are a "person entitled to enforce" under UCC 3-301, they may lack standing — and standing must be established before reaching other issues.

The Power of the Question

"Produce the original note with complete chain of endorsement" is not a magic phrase — but it IS a legitimate legal demand. If they can't answer it, you've found your leverage point.

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You know who can enforce and how to challenge them. Next: What did they actually give you? The consideration question.