Mich. Comp. Laws » Michigan Compiled Laws / Chapter 440 / Act 174 of 1962
Michigan Compiled Laws

Mich. Comp. Laws § 440.3204 (2026)

“Endorsement” and “endorser” defined; transfer of security interest effective as unqualified endorsement; instrument payable to name other than holder.

✓ current as of July 2026
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UNIFORM COMMERCIAL CODE


Act 174 of 1962


440.3204 “Endorsement” and “endorser” defined; transfer of security interest effective as unqualified endorsement; instrument payable to name other than holder.

Sec. 3204.

    (1)  "Endorsement" means a signature, other than that of a signer as maker, drawer, or acceptor, that alone or accompanied by other words is made on an instrument for the purpose of (i) negotiating the instrument, (ii) restricting payment of the instrument, or (iii) incurring endorser's liability on the instrument, but regardless of the intent of the signer, a signature and its accompanying words is an endorsement unless the accompanying words, terms of the instrument, place of the signature, or other circumstances unambiguously indicate that the signature was made for a purpose other than endorsement. For the purpose of determining whether a signature is made on an instrument, a paper affixed to the instrument is a part of the instrument.

    (2) "Endorser" means a person who makes an endorsement.

    (3) For the purpose of determining whether the transferee of an instrument is a holder, an endorsement that transfers a security interest in the instrument is effective as an unqualified endorsement of the instrument.

    (4) If an instrument is payable to a holder under a name that is not the name of the holder, endorsement may be made by the holder in the name stated in the instrument or in the holder's name or both, but signature in both names may be required by a person paying or taking the instrument for value or collection.

History: 1962, Act 174, Eff. Jan. 1, 1964 ;-- Am. 1993, Act 130, Eff. Sept. 30, 1993

Notes of Decisions
Cited in 6 cases (1 in the last 5 years), 1992–2024 · leading case: Livonia Prop. Holdings, L.L.C. v. 12840-12976 Farmington Road Holdings, L.L.C., 717 F. Supp. 2d 724 (E.D. Mich. 2010).
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Livonia Prop. Holdings, L.L.C. v. 12840-12976 Farmington Road Holdings, L.L.C., 717 F. Supp. 2d 724 (E.D. Mich. 2010). · cites it 4× “§ 440.3204. A 1993 amendment to that section added the sentence, “For the purpose of determining whether a signature is made on an instrument, a paper affixed to the instrument is *734 part of the instrument.”
JGMM Realty, LLC v. LNR Partners, LLC, 701 F. App'x 465 (6th Cir. 2017). “Plaintiff does not argue that the allonges did not constitute valid endorsements under Mich. Comp. Laws § 440.3204 (1). Plaintiff, who acknowledges the corrective assignment only in its reply brief, offers no reason to doubt its authenticity or defendants’ assertions regarding…”
Michigan Ins. Repair Co. v. Mfrs. Nat'l Bank, 487 N.W.2d 517 (Mich. Ct. App. 1992). “” MCL 440.3204(2); MSA 19.3204(2). Thus, plaintiff could not become a holder with the right to negotiate the check until it had been indorsed by all the named payees.”
Altson v. Loancare (E.D. Mich. 2024). · cites it 3× “” Instead, indorsement is governed by Mich. Comp. Laws § 440.3204 , which states that “[f]or the purpose of determining whether a signature is made on an instrument, a paper affixed to the instrument is a part of the instrument.”
in Re Est. of Ilko Podolak (Mich. Ct. App. 2017). “In making this argument, Mike cites to MCL 440.3204(1), which governs the definitions of “endorsement” and “endorser” but does not in any event support Mike’s argument that a simple signature indicates an endorsement only for the purposes of deposit.”
in Re Est. of Ilko Podolak (Mich. Ct. App. 2017). “In making this argument, Mike cites to MCL 440.3204(1), which governs the definitions of “endorsement” and “endorser” but does not in any event support Mike’s argument that a simple signature indicates an endorsement only for the purposes of deposit.”
— Mich. Comp. Laws § 440.3204(1) — 3 cases
Livonia Prop. Holdings, L.L.C. v. 12840-12976 Farmington Road Holdings, L.L.C., 717 F. Supp. 2d 724 (E.D. Mich. 2010). “§ 440.3204. A 1993 amendment to that section added the sentence, “For the purpose of determining whether a signature is made on an instrument, a paper affixed to the instrument is *734 part of the instrument.”
in Re Est. of Ilko Podolak (Mich. Ct. App. 2017). “In making this argument, Mike cites to MCL 440.3204(1), which governs the definitions of “endorsement” and “endorser” but does not in any event support Mike’s argument that a simple signature indicates an endorsement only for the purposes of deposit.”
in Re Est. of Ilko Podolak (Mich. Ct. App. 2017). “In making this argument, Mike cites to MCL 440.3204(1), which governs the definitions of “endorsement” and “endorser” but does not in any event support Mike’s argument that a simple signature indicates an endorsement only for the purposes of deposit.”
— Mich. Comp. Laws § 440.3204(2) — 1 case
Michigan Ins. Repair Co. v. Mfrs. Nat'l Bank, 487 N.W.2d 517 (Mich. Ct. App. 1992). “” MCL 440.3204(2); MSA 19.3204(2). Thus, plaintiff could not become a holder with the right to negotiate the check until it had been indorsed by all the named payees.”
— Mich. Comp. Laws § 440.3204(3) — 1 case
Livonia Prop. Holdings, L.L.C. v. 12840-12976 Farmington Road Holdings, L.L.C., 717 F. Supp. 2d 724 (E.D. Mich. 2010). “§ 440.3204. A 1993 amendment to that section added the sentence, “For the purpose of determining whether a signature is made on an instrument, a paper affixed to the instrument is *734 part of the instrument.”
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