Colorado Revised Statutes

Colo. Rev. Stat. § 4-3-201 (2026)

Negotiation

✓ current as of July 2026
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(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.

(b) Except for negotiation by a remitter, if an instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement by the holder. If an instrument is payable to bearer, it may be negotiated by transfer of possession alone.

Source: L. 94: Entire article R&RE, p. 850, § 1, effective January 1, 1995.

Editor's note: This section is similar to former § 4-3-202 as it existed prior to 1994.

Notes of Decisions
Cited in 11 cases, 1981–2015 · leading case: Pierce v. DeZeeuw, 824 P.2d 97 (Colo. Ct. App. 1991).
Pierce v. DeZeeuw, 824 P.2d 97 (Colo. Ct. App. 1991). · cites it 22× “” (emphasis added) Official Comment 6 of § 4-3-201, C.R.S. states that: “[T]he transferee acquires, in the absence of any agreement to the contrary, the right to have the indorsement of the transferor.”
In re Sandrin, 536 B.R. 309 (Bankr.D. Colo. 2015). · cites it 6× “Colo.Rev.Stat. § 4-3-201(a). The requirement of possession prevents multiple “claimants from qualifying as holders who could take free of the other party’s claim of ownership.”
Kelly v. Cent. Bank & Trust Co. of Denver, 794 P.2d 1037 (Colo. Ct. App. 1990). · cites it 2× “See §§ 4-3-201, 4-3-202, and 4-3-401, C.R.S.; Central, Inc.”
Pay Ctr., Inc. v. Milton, 632 P.2d 642 (Colo. Ct. App. 1981). · cites it 2× “The language of § 4-3-201, C.R.S. 1973, does not alter the rights of the transferee in this respect.”
La Junta State Bank v. Travis, 727 P.2d 48 (Colo. 1986). “§§ 4-3-201, -202. The latter type of transfer is pertinent to this inquiry.”
Armstrong v. Armstrong, 714 F. Supp. 451 (D. Colo. 1989). · cites it 2× “See § 4-3-201, C.R.S. These rights are free from any § 4-3-306(b), C.”
Repub. Nat'l Bank v. Meridian Props., Inc., 530 F. Supp. 169 (D. Colo. 1982). · cites it 4× “C.R.S. § 4-3-201(1) provides, in relevant part: Transfer of an instrument vests in the transferee such rights as the transferor has therein, .”
West Greeley Nat'l Bank v. Wygant, 650 P.2d 1339 (Colo. Ct. App. 1982). · cites it 2× “clause specifically conditioned payment to Wygant on death of the owner, thus taking the instrument out of § 4-3-104 for purposes of requiring Wygant’s endorsement under § 4-3-201, C.R.S. 1973. Judgment affirmed.”
Barclay Receivables Co. v. Mountain Majesty, Ltd., 903 P.2d 37 (Colo. Ct. App. 1995). “2d 64 (1971) (transferee of note assumes the same rights as transferor even without endorsement from transferor); see also §§ 4-3-201 & 4-3-301, C.R.S. (1992 Repl.Vol.”
Hollemon v. Murray, 666 P.2d 1107 (Colo. Ct. App. 1982). · cites it 2× “1973, and Official Comment 2 thereto; § 4-3-201(2), C.R.S.1973, and Official Comments 4 and 5 thereto; § 4-9-101 et seq.”
Travis v. La Junta State Bank, 694 P.2d 350 (Colo. Ct. App. 1984). · cites it 2× “If, when Warnock delivered the check to Quick, the additional words were not on it, it could be said that at that time he became a transferee under § 4-3-201, C.R.S., was a holder in due course under § 4-3-302, C.”
— Colo. Rev. Stat. § 4-3-201(1) — 2 cases
Repub. Nat'l Bank v. Meridian Props., Inc., 530 F. Supp. 169 (D. Colo. 1982). “C.R.S. § 4-3-201(1) provides, in relevant part: Transfer of an instrument vests in the transferee such rights as the transferor has therein, .”
Pierce v. DeZeeuw, 824 P.2d 97 (Colo. Ct. App. 1991). “” (emphasis added) Official Comment 6 of § 4-3-201, C.R.S. states that: “[T]he transferee acquires, in the absence of any agreement to the contrary, the right to have the indorsement of the transferor.”
— Colo. Rev. Stat. § 4-3-201(2) — 1 case
Hollemon v. Murray, 666 P.2d 1107 (Colo. Ct. App. 1982). “1973, and Official Comment 2 thereto; § 4-3-201(2), C.R.S.1973, and Official Comments 4 and 5 thereto; § 4-9-101 et seq.”
— Colo. Rev. Stat. § 4-3-201(3) — 1 case
Pierce v. DeZeeuw, 824 P.2d 97 (Colo. Ct. App. 1991). “” (emphasis added) Official Comment 6 of § 4-3-201, C.R.S. states that: “[T]he transferee acquires, in the absence of any agreement to the contrary, the right to have the indorsement of the transferor.”
— Colo. Rev. Stat. § 4-3-201(a) — 1 case
In re Sandrin, 536 B.R. 309 (Bankr.D. Colo. 2015). “Colo.Rev.Stat. § 4-3-201(a). The requirement of possession prevents multiple “claimants from qualifying as holders who could take free of the other party’s claim of ownership.”
— Colo. Rev. Stat. § 4-3-201(b) — 1 case
In re Sandrin, 536 B.R. 309 (Bankr.D. Colo. 2015). “Colo.Rev.Stat. § 4-3-201(a). The requirement of possession prevents multiple “claimants from qualifying as holders who could take free of the other party’s claim of ownership.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.