Delaware Code

6 Del. C. § 3-205 (2026)

Special indorsement; blank indorsement; anomalous indorsement

✓ current as of May 2026

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(a) If an indorsement is made by the holder of an instrument, whether payable to an identified person or payable to bearer, and the indorsement identifies a person to whom it makes the instrument payable, it is a “special indorsement.” When specially indorsed, an instrument becomes payable to the identified person and may be negotiated only by the indorsement of that person. The principles stated in Section 3-110 apply to special indorsements.

(b) If an indorsement is made by the holder of an instrument and it is not a special indorsement, it is a “blank indorsement.” When indorsed in blank, an instrument becomes payable to bearer and may be negotiated by transfer of possession alone until specially indorsed.

(c) The holder may convert a blank indorsement that consists only of a signature into a special indorsement by writing, above the signature of the indorser, words identifying the person to whom the instrument is made payable.

(d) “Anomalous indorsement” means an indorsement made by a person who is not the holder of the instrument. An anomalous indorsement does not affect the manner in which the instrument may be negotiated.

5A Del. C. 1953, §§ 3-204; 55 Del. Laws, c. 349; 70 Del. Laws, c. 86, § 3;

Notes of Decisions

Cited in 5 cases (1 in the last 5 years), 2009–2024 · leading case: Travelers Cas. & Sur. Co. of Am. v. Bancorp Bank, 691 F. Supp. 2d 531 (D. Del. 2009).

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Travelers Cas. & Sur. Co. of Am. v. Bancorp Bank, 691 F. Supp. 2d 531 (D. Del. 2009). · cites it 2× “8 See 6 Del. C. § 3-205(d). When defendant put its stamp of indorsement on the back of the disputed checks, the checks became properly payable because defendant was named as the checks’ payee.”

Bank of New York Mellon v. Pearson (Del. Super. Ct. 2017). “” However, Defendant does not explain this terminology or provide any support to suggest that the signatures on the assignments are invalid.”

The Bank of New York Mellon v. Shrewsbury (Del. Super. Ct. 2018). “17 6 Del. C. § 3-205. 5 to enforce the note against the maker.”

Bank of New York Mellon v. Tang (Del. Super. Ct. 2019). “14 Moving to Defendant’s second argument regarding the assignment by MERS, Delaware Courts show little appetite for invalidating mortgage assignments merely because they were assigned by MERS.”

The Bank of New York Mellon v. Pearson (Del. Super. Ct. 2024). “§ 3-301; 6 Del. C. § 3-205. 4 JUDGMENT is entered in favor of Plaintiff The Bank of New York Mellon and against Defendant.”

— 6 Del. C. § 3-205(d) — 1 case

Travelers Cas. & Sur. Co. of Am. v. Bancorp Bank, 691 F. Supp. 2d 531 (D. Del. 2009). “8 See 6 Del. C. § 3-205(d). When defendant put its stamp of indorsement on the back of the disputed checks, the checks became properly payable because defendant was named as the checks’ payee.”

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