Florida Statutes

Fla. Stat. § 673.2051 (2025)

Special indorsement; blank indorsement; anomalous indorsement.

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673.2051 Special indorsement; blank indorsement; anomalous indorsement.—

(1) 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 s. 673.1101 apply to special indorsements.

(2) 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.

(3) 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.

(4) The term “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.

History.—s. 2, ch. 92-82.

Notes of Decisions

Cited in 49 cases (2 in the last 5 years), 2010–2024 · leading case: Harvey v. Deutsche Bank Nat'l Trust Co., 69 So. 3d 300 (Fla. 4th DCA 2011).

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Harvey v. Deutsche Bank Nat'l Trust Co., 69 So. 3d 300 (Fla. 4th DCA 2011). · cites it 8× “§ 673.2051(1), Fla. Stat. (2008). Because *304 it was not a special indorsement, the indorsement was a "blank indorsement," which made the note "payable to bearer" and allowed the note to be "negotiated by transfer of possession alone.”

Riggs v. Aurora Loan Servs., LLC, 36 So. 3d 932 (Fla. 4th DCA 2010). · cites it 4× “§ 673.2051(1), Fla. Stat. (2008). Because it was not a special in-dorsement, the indorsement was a “blank indorsement,” which made the note “payable to bearer” and allowed the note to be “negotiated by transfer of possession alone.”

Brindise v. U.S. Bank Nat'l Ass'n, 183 So. 3d 1215 (Fla. 2d DCA 2016). · cites it 4× “See § 673.2051(2), Fla. Stat. (2014) ("If an indorsement is made by the holder of an instrument and it is not a special indorsement, it is a 'blank indorsement.”

Gorel v. Bank of New York Mellon, 165 So. 3d 44 (Fla. 5th DCA 2015). · cites it 3× “Section 673.2051(1), Florida Statutes (2013), provides that [i]f 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…”

PennyMac Corp. v. Frost, 214 So. 3d 686 (Fla. 4th DCA 2017). · cites it 4× “§ 673.2051(2), Fla. Stat. (2015). An indorsement “made by a person who is not the holder” of the note is defined as an “anomalous indorsement.”

Sandra A. Forero & William L. Forero v. Green Tree Servicing, LLC, 223 So. 3d 440 (Fla. 1st DCA 2017). · cites it 2× “See § 673.2051(2), Fla. Stat.; see also §§ 671.”

Anastacia S. Lacombe & Max P. Lacombe v. Deutsche Bank Nat'l Trust Co., etc., 149 So. 3d 152 (Fla. 1st DCA 2014). · cites it 2× “§ 673.2051(1), Fla. Stat. Negotiation of the note thus required both possession and an indorsement by Long Beach Mortgage Company.”

Dixon v. Express Equity Lending Grp., LLLP, 125 So. 3d 965 (Fla. 4th DCA 2013). · cites it 2× “Section 673.2051(1), Florida Statutes (2009), provides, in pertinent part: 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…”

Deutsche Bank Nat'l Trust Co. v. Lippi, 78 So. 3d 81 (Fla. 5th DCA 2012). · cites it 2× “Pursuant to section 673.2051(2), Florida Statutes, the note was payable to the bearer and could be transferred simply by possession.”

Houk v. PennyMac Corp., 210 So. 3d 726 (Fla. 2d DCA 2017). · cites it 2× “In the Lamb case, the Fourth District outlined what a substituted plaintiff seeking to enforce an instrument indorsed to the original plaintiff must establish as follows: “When specially indorsed, an instrument becomes payable to the identified person and may be negotiated only…”

Craig D. Lamb v. Nationstar Mortg., LLC, 174 So. 3d 1039 (Fla. 4th DCA 2015). · cites it 2× “” There was no other testimony on the issue of Nationstar’s standing. The original note was lost and the copy placed into evidence was specially indorsed to Aurora.”

Wells Fargo Bank, N.A. v. Morcom, 125 So. 3d 320 (Fla. 5th DCA 2013). · cites it 2× “4th DCA 2011)); see also § 673.2051, Fla. Stat. (2010). In the present case, the original note Appellant attached was endorsed in blank with Appellant’s name stamped in the blank endorsement field, which, paired with section 673.”

Show all 49 citing cases →

— 673.2051(1) — 21 cases

Harvey v. Deutsche Bank Nat'l Trust Co., 69 So. 3d 300 (Fla. 4th DCA 2011). “§ 673.2051(1), Fla. Stat. (2008). Because *304 it was not a special indorsement, the indorsement was a "blank indorsement," which made the note "payable to bearer" and allowed the note to be "negotiated by transfer of possession alone.”

Gorel v. Bank of New York Mellon, 165 So. 3d 44 (Fla. 5th DCA 2015). “Section 673.2051(1), Florida Statutes (2013), provides that [i]f 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…”

Riggs v. Aurora Loan Servs., LLC, 36 So. 3d 932 (Fla. 4th DCA 2010). “§ 673.2051(1), Fla. Stat. (2008). Because it was not a special in-dorsement, the indorsement was a “blank indorsement,” which made the note “payable to bearer” and allowed the note to be “negotiated by transfer of possession alone.”

Anastacia S. Lacombe & Max P. Lacombe v. Deutsche Bank Nat'l Trust Co., etc., 149 So. 3d 152 (Fla. 1st DCA 2014). “§ 673.2051(1), Fla. Stat. Negotiation of the note thus required both possession and an indorsement by Long Beach Mortgage Company.”

Dixon v. Express Equity Lending Grp., LLLP, 125 So. 3d 965 (Fla. 4th DCA 2013). “Section 673.2051(1), Florida Statutes (2009), provides, in pertinent part: 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…”

— 673.2051(2) — 25 cases

Brindise v. U.S. Bank Nat'l Ass'n, 183 So. 3d 1215 (Fla. 2d DCA 2016). “See § 673.2051(2), Fla. Stat. (2014) ("If an indorsement is made by the holder of an instrument and it is not a special indorsement, it is a 'blank indorsement.”

Sandra A. Forero & William L. Forero v. Green Tree Servicing, LLC, 223 So. 3d 440 (Fla. 1st DCA 2017). “See § 673.2051(2), Fla. Stat.; see also §§ 671.”

Deutsche Bank Nat'l Trust Co. v. Lippi, 78 So. 3d 81 (Fla. 5th DCA 2012). “Pursuant to section 673.2051(2), Florida Statutes, the note was payable to the bearer and could be transferred simply by possession.”

— 673.2051(3) — 4 cases

HSBC Bank USA v. Buset, 241 So. 3d 882 (Fla. 3d DCA 2018).

Deutsche Bank Nat'l Trust Co. v. Mobley, 212 So. 3d 511 (Fla. 3d DCA 2017).

Aquasol Condo Assoc. v. HSBC Bank USA (Fla. 3d DCA 2018).

— 673.2051(4) — 5 cases

U.S. Bank Nat'l Ass'n v. Becker, 211 So. 3d 142 (Fla. 4th DCA 2017).

PennyMac Corp. v. Frost, 214 So. 3d 686 (Fla. 4th DCA 2017). “§ 673.2051(2), Fla. Stat. (2015). An indorsement “made by a person who is not the holder” of the note is defined as an “anomalous indorsement.”

Buckingham v. Bank of Am., N.A., 230 So. 3d 923 (Fla. 2d DCA 2017).

Deutsche Bank Nat'l Trust, Etc. v. Fleming Harris (Fla. 4th DCA 2020).

Catherine P. Cox v. U.S. Bank, Trust N.a., as Tr. for Lsf9 Master Participation Trust (Fla. 4th DCA 2020).

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