Frey paid Holt $2,500 by check pursuant to an agreement between them whereby Holt promised to perform in Frey's theatre within the next year. Holt Indorsed the check, making it payable to Len Able. Holt's status with regard to the check was one of a(n) a. Assignee since a payee may not also be a holder in due course. b. Holder since Holt's promise failed to satisfy the value requirement necessary to become a holder in due course. c. Holder in due course under the shelter rule since Able's rights as a holder in due course revert to Holt. d. Holder in due course since all the requirements have been satisfied