Ollie was the owner in fee simple of a parcel of realty known as Oldacre. On May 1, Ollie executed two deeds. Deed #1 purported to grant an undivided one-quarter interest in Oldacre to Ollie's friend Frank. Deed #2 purported to grant an undivided one-quarter interest in Oldacre to Ollie's nephew Newman. On May 1, Ollie handed Frank Deed #1, saying, "Because you have been a good and faithful friend for all these years, I'm giving you this deed. But it isn't to take effect until after my death." Frank thanked Ollie and took the deed. On May 2, Ollie sent for his nephew Newman. He said, "I was planning to leave you an interest in Oldacre in my will, but I see no reason why you should have to pay inheritance tax. So I'll give it to you while I'm still alive if you promise to move in here with me some time during the next year." Newman promised that he would do so, and Ollie gave him Deed #2, saying, "Then it's yours." Newman read the deed, thanked Ollie, and handed the deed back to Ollie for safekeeping. Ollie placed it in a drawer of his desk. On May 7, Ollie argued with Newman. Angry, Ollie tore Deed #2 into eight pieces and returned them to his desk drawer. On May 10, Ollie died, leaving no will. Following Ollie's death, Frank and Newman each claimed a right to an undivided one-quarter interest in Oldacre. The administrator of Ollie's estate denied both claims. If Frank seeks a judicial declaration that he held a possessory interest in Oldacre on Ollie's death which would be his most effective argument:

Select one:

a. Frank's possession of Deed

b. On May 1 Frank received a remainder interest in Oldacre.

c. The deed was a testamentary substitute.

d. Ollie's death completed delivery of the deed.