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The bona fide holder is not affected by any issues between antecedent
parties. Pre-existing debt does constitute a valuable consideration
applicable to negotiable instruments. J. Story uses policy to state the
reasons why:
1. It is for the benefit and convenience of the commercial world to
give as wide an extent as practicable to the credit and circulation of
negotiable paper . . . in payment of, and as security for, pre-existing
debts.
a. This will allow creditors to secure their debts and safely
offer prolonged credit.
b. To use the NY rule would "strike a fatal blow at all discounts
of negotiable securities for pre-existing debts."