Project on Negotiability and Electronic Commerce ABA Science and Technology Section
Electronic Commerce Division
Subcommittee on Electronic Commercial Payments
Chair, Richard Field, Esq.
Reporter, Professor Jane K. Winn, SMU School of Law

with
ABA Business Law Section
Committee on Cyberspace Law

I. Introduction: Description of Project on Negotiability and Electronic Commerce

II. Application of Principles of Negotiability in Traditional and Emerging Transfer and Payment Systems

III. Proposed Media Neutral Language for Recognizing Electronic Equivalent of Negotiability by Contract and by Statute

IV. Annotated Bibliography


 I. Introduction: Description of Project on Negotiability and Electronic Commerce

A. [describe work of ECP Subcommittee in cataloging examples of transfer and payment systems posted on World Wide Web site]

B. [describe preparation of Report based on analysis of examples provided by members and proposed media neutral language for recognizing electronic equivalent of negotiability by contract and by statute]



II. Application of Principles of Negotiability in Traditional and Emerging Transfer and Payment Systems

A. What is negotiability? - a working definition for the purposes of this Project
1. Paper merges with abstract rights
2. Use of form invokes legal rules simplifying transfer of ownership
3. Use of form cuts off spectrum of defenses and competing claims by operation of law
4. Use of form invokes procedural advantages, including factual presumptions, in litigation after default
5. Use of form invokes loss allocation system without risk pooling that encourages use of decentralized, party-controlled risk management policies

B. Template for contributions to this Web site - please organize submissions along the following lines; if a particular section is not applicable to a given transfer or payment system, please note that but do not omit the subsection. All submissions must be submitted to Jane Winn at jwinn@mail.smu.edu.

Contributors will be listed by name and institutional affiliation, if applicable, and will be asked to provide an email address to permit dialogue among interested parties

C. Existing Transfer and Payment Systems Incorporating Principles of Negotiability

1. Negotiable Instruments under UCC 3 - contributor: Jane K. Winn, SMU School of Law, jwinn@mail.smu.edu

1. What is it? written contract - order or promise to pay to order or bearer with date and sum certain containing no forbidden terms

2. How is the right transferred? What is the source of law governing the mechanics of transfer?
Merger rule - paper and right merge
Negotiate - bearer negotiable by transfer of possession, order paper by endorsement of holder; creates another holder
Transfer - voluntary surrender of possession that does not meet all the requirements of negotiation
Person entitled to enforce & Shelter- a transferee who is not a holder may still be entitled to enforce the instrument and may shelter under the rights of the transferor

3. How are competing claims of ownership and contractual defenses handled? What is the source of law governing the enforceability of such claims and defenses when the rights have been transferred to third parties?
HDC takes free of claims and personal defenses, but not real defenses nor defect in title due to forged necessary indorsement; FTC rule protects consumers from HDC

4. How are the rights enforced in the hands of 3rd parties? What is the source of law governing such enforcement?
Presumption of genuine signatures

5. How are risks of fraud and error allocated? How are risks of nonpayment allocated? What is the source of law governing such loss allocation rules? How much power to parties have over their own risk management policies?
Warranty liability covers downstream transferees from risk of defect in title, forgery
Indorser's contract protects downstream transferees from risk of nonpayment
Contributory negligence for alternation or forgery, imposter, employee defalcation, bank statement rules

2. Negotiable Documents
3. Certificated Securities under UCC 8
4. Good Faith Secured Party under UCC 9
5. FDIC as HDC
6. Leasing - Hell or High Water provisions under UCC 2A
7. Contractual Waiver of Defenses under Common Law
8. ??



D. Existing Transfer and Payment Systems that Do Not Rely on Principles of Negotiability 1. Nonnegotiable Instruments
2. Nonnegotiable Documents
3. Funds Transfers (ACH, Fedwire, Chips) under UCC 4A - Jane Larimer, NACHA
4. Check collections under UCC 4
5. Credit Cards under Reg. Z - Catherine Lee Wilson, U. Nebraska-Lincoln
6. ACH - including EFT under Reg. E - Jane Larimer, NACHA
7. Securitization
8. European GIRO
9. Certificates of Title
10. Uncertificated Securities and Securities Entitlements under UCC 8
11. ??


E. Emerging Transfer and Payment Systems 1. Electronic Cotton Warehouse Receipts
2. MERS
3. Digital Signatures
4. Stored Value Cards  - Catherine Lee Wilson, U. Nebraska-Lincoln
5. Bolero and Electronic Documents of Title
6. Digicash and Chaumian Tokens
7. E-check - Janine Hiller, Virginia Tech
8. SET - Visa & MasterCard's Secure Electronic Transactions standard
9. ??


III. Proposed Media Neutral Language for Recognizing Electronic Equivalent of Negotiability by Contract and by Statute
A. Record [writing]
B. Transferrability [negotiability]
C. Control [possesson]
D. Protected Purchaser [holder in due course]
E. Public Notice of Transfer by Registry Entry? [perfection]
F. Warranty of Authenticity of Record from Registry? [uniqueness/good title]
G. Warranty of Authority from Owner to Transfer? [genuine signatures]
H. Warranty of No Defenses in Underlying Transaction?
I. Shelter Rule?
J. ??


IV. Annotated Bibliography

ABA Task Force on Stored Value Cards, A Commercial Lawyer's Take on the Electronic Purse: An Analysis of Commercial Law Issues Associated With Stored Value Cards and Electronic Money, 52 Business Lawyer 653 (1997).
The article examines the operation of stored value cards and electronic money and the extent to which analogies to more traditional payment systems, such as negotiable instruments, can inform their regulation.

Robert Charles Clark, Abstract Rights versus Paper Rights under Article 9 of the Uniform Commercial Code, 84 Yale L. J. 445 (1975)
Paper rights, which include promissory notes, stock certificates, warehouse receipts and chattel paper, are property rights that have been "concretized" in paper. These correspond to abstract rights include accounts, unembodied shareholder interests, interests in inventory or goods. This article analyzes the varying treatment under Article 9 of the priority of the interest of secured parties in these abstract rights that are wrongfully converted by the debtor into a paper right and then pledges the paper right to an innocent third party. In addition, this article discusses the evolution of the tendency to suppress abstraction in commercial law. In a society in which all rights are abstract (i.e., no paper or filing system), then nonpossessory rights will be difficult to establish and police. Paperizing rights can the terms of the right less ambiguous, and making a paper the unique embodiment of an abstract right can reduce fraud. The next step is the creation of a central recording or filing system in which the paper right, a copy of it or notice of it is kept. Such a recording system can substantially reduce fraud and error.
 
Robert D. Cooter and Edward L. Rubin, A Theory of Loss Allocation for Consumer Payments, 66 Tex. L. Rev. 63 (1987)
Legislation governing payment systems used by consumers adopts a variety of different approaches, some of which are mutually inconsistent. These different legislative approaches can be analyzed in terms of whether they promote economic efficiency. Markets in which consumers are present are inefficient if information asymmetries and disproportionate negotiating costs suffered by consumers but not businesses. Loss allocation rules should be designed in light of these market failures. Loss allocation rules include loss spreading, which permits economic actors to manage risk by creating a portfolio of risky assets that as an aggregate has a risk profile that the actor can accept from a large number of assets that each have risk profiles that individually are not acceptable to the actor; loss reduction rules create incentives for parties to minimize losses through precaution or innovation; and loss imposition rules enforce the assignment of liability to the party most able to manage risks according to the first two principles. If the object of regulation is to promote the economic efficiency of payment systems, then consumer liability for the amount of invalid checks paid by banks should mimic the consumer liability limits for invalid credit card payments.

Walter A. Effross, Putting the Cards Before the Purse?: Distinctions, Differences, and Dilemmas in the Regulation of Stored Value Card Systems, 65 UMKC L.Rev. 319 (1997).
        The article discusses the different types and features of stored value cards; examines the underlying tensions concerning the timing and extent of regulation in this area; reviews the legislative history and relevant
provisions of the Electronic Fund Transfer Act and Regulation E; analyzes the revisions proposed by the Federal Reserve Board of Governors in May 1996 to apply Regulation E to stored value systems; evaluates the responses submitted to the Board pursuant to its request for comment; analyzes the conclusions of the FDIC, and the financial community's response, concerning the insurability of funds held by depository institutions in exchange for stored value cards; reviews the recommendations of the Office of the Comptroller of the Currency on consumer disclosures in this context; and suggests principles and practices to develop a more effective set of regulatory classifications of stored value card systems.

David Frisch and Henry D. Gabriel, Much Ado About Nothing: Achieving Essential Negotiability in an Electronic Environment, 31 Idaho L. Rev. 747 (1995)
At the time that negotiable instruments law emerged, the common law of assignments prohibited assignments of contract rights; this prohibition continued generally until the 19th century. Under modern contract law, there is no longer any such prohibition. When compared to assignees of contract rights, holders of negotiable instruments still generally enjoy more simple enforcement procedures, and other advantages, such as the exclusive right to receive payments from the debtor, that make payment more certain. However, many of these advantages can be reproduced for assignees of contract rights by using provisions such as waivers of defenses, and the initial hostility of the common law to such drafting techniques is now gone. Given that even the transferee of a negotiable instrument may take subject to competing claims of ownership if a necessary indorsement has been forged, filing systems designed to support electronic commerce modeled after Article 9 filing offices might be adequate to protect assignees of contract rights in the future without negotiability.
 
Grant Gilmore, The Commercial Doctrine of Good Faith Purchase, 63 Yale L. J. 1057 (1954)
 
Grant Gilmore, Formalism and the Law of Negotiable Instruments, 13 Creighton L. Rev. 441 (1979)

Grant Gilmore, The Good Faith Purchase Idea and the Uniform Commercial Code: Confessions of a Repentant Draftsman, 15 Ga. L. Rev. 605 (1981)
 
Grant Gilmore, On Statutory Obsolesence, 39 Colo. L. Rev. 461 (1967)
Codification projects inevitably look backward and fail to predict what the future will hold. Some bodies of commercial law were well enough established with the creation at the turn of the century of the Uniform Law Commission to become the subject of individual statutes, such as the Uniform Sales Act. Once sales law was codified, it failed to take account of long-term contractual arrangements, such as requirements contracts, until the case law on sales was revisited with the drafting of the UCC fifty years later. Although the UCC tries to be flexible and ambiguous, it is inevitable that the same rigidities will become apparent with the UCC as new commercial practices develop.
 
Ronald J. Mann, Searching for Negotiability in Payment and Credit Systems, 44 U.C.L.A. 951 (1997)

Charles W. Mooney, Jr., Beyond Negotiability: A New Model for Transfers and Pledge of Interests in Securities Controlled by Intermediaries 12 Cardozo L. Rev. 305 (1990)

James A. Newell and Michael R. Gordon, Electronic Commerce and Negotiable Instruments (Electronic Promissory Notes) 31 Idaho L. Rev. 819 (1995)
 
Henry H. Perritt, Jr. Legal and Technological Infrastructures for Electronic Payment Systems, 22 Rutgers Computer & Tech. L. J. 1 (1996)
 
Marie T. Reilly, The FDIC as Holder in Due Course: Some Law and Economics, 1992 Colum. Bus. L. Rev. 165
The FDIC has 3 legal bases for its federal HDC status: D'Oench Duhume, 12 USC § 823(e) and federal common law. FDIC immunity from defenses of bank customer arises in the when FDIC as receiver takes over a failed bank, and serves to lower the cost to the FDIC (and possibly the taxpayer) of a successful disposition of the assets of the failed bank. Federal HDC status for the FDIC is economically efficient if the losses imposed on the failed bank's customers are losses that the customers could more easily have avoided before the bank's failure than the FDIC could have taken account of them after the bank's failure.
 
James Steven Rogers, The Irrelevance of Negotiable Instruments Concepts in the Law of Check-Based Payment Systems, 65 Tex. L. Rev. 929 (1987)
It is often wrongly assumed that the modern check collection system requires the following three effects of applying negotiable instruments law: standardization of the rights and obligations of the parties to a check; the reification of the payment obligation in a piece of paper; and the ability of certain transferees to take the check free from certain claims or defenses that other parties to the check might raise. While negotiability helps explain a payment system based on bank notes, it does not help explain a payment system based on instructions to withdraw funds from deposit accounts. The check collection system is based on legal principles, such as provisional settlements that firm up and banks acting as agents for their depositors, that offer a complete explanation of the operation of the check collection system and its loss allocation rules without reference to negotiability.

James Steven Rogers, The Myth of Negotiability, 31 Boston College L. Rev. 265 (1990)

James Steven Rogers, Negotiability as a System of Title Recognition, 48 Ohio State L. Rev. 197 (1987)
It is a common misperception among lawyers that negotiable instruments law deals with a unique form of property, whose salient characteristic is its value to strangers who qualify as holders in due course because they can cut off the claims and defenses of other innocent parties in the event of an unexpected loss. This overlooks the importance of negotiability as a system of title recognition; any system of title recognition will favor those who comply with its terms over those who do not. Negotiability effectively creates a "last in time, first in right" rule to resolve disputes, except when there is a forged necessary indorsement. As a result, negotiability creates less certainty in commercial transactions than is commonly assumed. A recording system would permit parties to discover competing claims of ownership prior to purchasing the asset, and so reduce the number of times losses must be allocated between innocents.
 
James Steven Rogers, Policy Perspectives on Revised U.C.C. Article 8, 43 U.C.L.A. 1431 (1996)
 
Hal S. Scott, The Risk Fixers, 91 Harv. L. Rev. 737 (1978)
 
Albert J. Rosenthal, Negotiability - Who Needs It? 71 Colum. L. Rev 375 (1971)
Holder in due course allocates losses between two innocents; the problem arises because the wrongdoer cannot be made to bear the losses he or she caused. Given that splitting the difference has not historically been an option, the apparent inequity of the result is justified by reference to the need to protect the buyer's reasonable expectations in order to promote the growth of markets and commerce. Law professors emphasize the remarkable nature of HDC to spark the interest of law students in what would otherwise be a dull course; HDC doctrines can be especially unfair when applied to consumers. Negotiability doctrines fail to take account of the realities of the modern check collection system.

Jane K. Winn, Couriers Without Luggage:  Negotiable Instruments and Digital Signatures, 49 S. Carolina L. Rev. 900 (1998) www.smu.edu/~jwinn/ecourier.htm
While the origins of negotiable instruments can be traced back to the late medieval period, and digital signatures created using public key cryptography were not invented until the 1970s and are only coming into widespread commercial use in the late 1990s, they share certain common features.  Both are techniques that can be used to solve certain predictable problems encountered by parties to commercial transactions.  Negotiable instruments law is characterized by a high degree of formalism and encourages parties to take responsibility for the fraud and error risks associated with commercial transactions.  The ABA Digital Signature Guidelines, published in 1996, propose that the regulation of digital signatures might usefully be analogized to negotiable instruments.  While this analogy is very suggestive of certain features negotiable instruments and digital signatures share, ultimately it is a flawed analogy.  The structure of negotiable instruments law reflectes centuries of commercial practice, while there are not yet any large-scale applications for digital signatures.  Legislating rigid loss allocation rules for digital signatures is premature at this time, because there is not yet any significant commercial experience with this technology to indicate whether such a loss allocation system makes sense.

Jane K. Winn, Open Systems, Free Markets and the Regulation of Internet Commerce, 72 Tulane L. Rev. 1 (1998) www.smu.edu/~jwinn/esig.htm
While conducting business over the Internet raises many novel issues of commercial practice, it is not clear that the appropriate legislative response should be new laws designed to promote Internet electronic commerce.  One of the most hotly debated issues regarding the regulation of Internet commerce is the question of what would be the online equivalent of a signature. Technology specific legislation designed to promote the use of public key cryptography has been vigorously promoted in many quarters, but upon careful examination, can be seen to suffer from serious shortcomings.  A technology-neutral approach to Internet commerce legislation is preferable because it permits parties to commercial transactions to make up their own minds about what new business practices make sense for Internet commerce. If any special legislation is needed to promote sound business practices in Internet commerce at this early stage in its development, it would be technology-neutral consumer protection legislation, not protections for technology developers and promoters before the risks associated with their products have become apparent.