Ohio Revised Code

Ohio Rev. Code § 1303.10 (2026)

Payable to bearer or to order - UCC 3-109

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(A) A promise or order is "payable to bearer" if any of the following apply:

(1) It states that it is payable to the bearer or to the order of bearer or otherwise indicates that the person in possession of the promise or order is entitled to payment.

(2) It does not state a payee.

(3) It states that it is payable to "cash" or to the order of "cash" or otherwise indicates that it is not payable to an identified person.

(B) A promise or order that is not payable to bearer is payable to order if it is payable to the order of an identified person or to an identified person or order.

(C) A promise or order that is payable to order is payable to the identified person.

(D) An instrument payable to bearer may become payable to an identified person if it is specially indorsed pursuant to division (A) of section 1303.25 of the Revised Code. An instrument payable to an identified person may become payable to the bearer if it is indorsed in blank pursuant to division (B) of section 1303.25 of the Revised Code.

Notes of Decisions
Cited in 13 cases (1 in the last 5 years), 1988–2025 · leading case: Wells Fargo Bank, N.A. v. Odita, 2014-Ohio-2540.
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Wells Fargo Bank, N.A. v. Odita, 2014-Ohio-2540. · cites it 2× “R.C. 1303.10(C). The law provides that an instrument payable to an identified person may become payable to bearer if it is indorsed in blank.”
U.S. Bank Nat'l Ass'n v. Courthouse Crossing Acquisitions, LLC, 2017-Ohio-9231, 101 N.E.3d 1243. · cites it 2× “" R.C. 1303.10(C). "An instrument, when specially indorsed, becomes payable to the identified person and may be negotiated only by the indorsement of that person.”
Klingshirn v. Westview Concrete Corp., 680 N.E.2d 691 (Ohio Ct. App. 9th Dist. 1996). “” R.C. 1303.10(A). The coupons, which do not state a specific payee, are thus payable to the bearer thereof; in this case, the person in possession of the coupons, i.”
In re Moehring, 485 B.R. 571 (Bankr. S.D. Ohio 2013). · cites it 2× “. The Debtor's legal counsel filed a motion to withdraw as counsel on March 12, 2012, which the court granted after a hearing on May 4, 2012 (docs.”
In re Smoak, 461 B.R. 510 (Bankr. S.D. Ohio 2011). “See also Ohio Revised Code § 1303.10(D) (“An instrument payable to an identified person may become payable to bearer if it is indorsed in blank pursuant to [1303.”
Fed. Natl. Mtge. Assn. v. Brown, 2017-Ohio-9237. “R.C. 1303.10(A)(2). As such, Fannie Mae was required to show it had possession of the note when it filed the foreclosure complaint.”
G.F.D. Enter., Inc. v. Nye, 525 N.E.2d 10 (Ohio 1988). “09 and Official Comment 2 to R.C. 1303.10. R.C. 1303.32(A) provides: “A holder takes the instrument for value: “(A) to the extent the agreed consideration has been performed or that he acquires a security interest in or a lien on the instrument otherwise than by legal process[.”
Bank of Am., N.A. v. McCormick, 2014-Ohio-1393. “201(A)(21)(a) and R.C. 1303.10(A)(2). Further, a party may gain interest in a note or mortgage through a chain of mergers.”
U.S. Bank Trust, N.A. v. Jacobs, 2015-Ohio-4632. “{¶ 18} Appellee’s possession of the note was evidenced by a copy of the note attached to the complaint and the affidavit to appellee’s motion for summary judgment.”
Bayview Loan Servicing, L.L.C. v. Big Blue Capital Partners, L.L.C., 2016-Ohio-3433. “201(B)(21)(a) and R.C. 1303.10(A)(2). Here, the loan 5 documents indicate that Bank of America, N.”
CitiMortgage, Inc. v. Teofilo, 2016-Ohio-334. “R.C. 1303.10(A)(2). In response to appellee’s summary judgment motion, appellant argued that Freddie Mac was the true “owner” of the loan.”
1900 Capital Trust II v. House-Redd, 2025-Ohio-3274, 272 N.E.3d 1252. “See R.C. 1303.10(A)(2) (a promise or order to pay is considered bearer paper if it does not specify a payee); see also R.”
Show all 13 citing cases →
Ohio Rev. Code § 1303.10(A): 2 cases
Klingshirn v. Westview Concrete Corp., 680 N.E.2d 691 (Ohio Ct. App. 9th Dist. 1996). “” R.C. 1303.10(A). The coupons, which do not state a specific payee, are thus payable to the bearer thereof; in this case, the person in possession of the coupons, i.”
In re Moehring, 485 B.R. 571 (Bankr. S.D. Ohio 2013). “. The Debtor's legal counsel filed a motion to withdraw as counsel on March 12, 2012, which the court granted after a hearing on May 4, 2012 (docs.”
Ohio Rev. Code § 1303.10(A)(2): 7 cases
Fed. Natl. Mtge. Assn. v. Brown, 2017-Ohio-9237. “R.C. 1303.10(A)(2). As such, Fannie Mae was required to show it had possession of the note when it filed the foreclosure complaint.”
Bank of Am., N.A. v. McCormick, 2014-Ohio-1393. “201(A)(21)(a) and R.C. 1303.10(A)(2). Further, a party may gain interest in a note or mortgage through a chain of mergers.”
U.S. Bank Trust, N.A. v. Jacobs, 2015-Ohio-4632. “{¶ 18} Appellee’s possession of the note was evidenced by a copy of the note attached to the complaint and the affidavit to appellee’s motion for summary judgment.”
Bayview Loan Servicing, L.L.C. v. Big Blue Capital Partners, L.L.C., 2016-Ohio-3433. “201(B)(21)(a) and R.C. 1303.10(A)(2). Here, the loan 5 documents indicate that Bank of America, N.”
CitiMortgage, Inc. v. Teofilo, 2016-Ohio-334. “R.C. 1303.10(A)(2). In response to appellee’s summary judgment motion, appellant argued that Freddie Mac was the true “owner” of the loan.”
Ohio Rev. Code § 1303.10(C): 2 cases
Wells Fargo Bank, N.A. v. Odita, 2014-Ohio-2540. “R.C. 1303.10(C). The law provides that an instrument payable to an identified person may become payable to bearer if it is indorsed in blank.”
U.S. Bank Nat'l Ass'n v. Courthouse Crossing Acquisitions, LLC, 2017-Ohio-9231, 101 N.E.3d 1243. “" R.C. 1303.10(C). "An instrument, when specially indorsed, becomes payable to the identified person and may be negotiated only by the indorsement of that person.”
Ohio Rev. Code § 1303.10(D): 4 cases
In re Smoak, 461 B.R. 510 (Bankr. S.D. Ohio 2011). “See also Ohio Revised Code § 1303.10(D) (“An instrument payable to an identified person may become payable to bearer if it is indorsed in blank pursuant to [1303.”
Wells Fargo Bank, N.A. v. Odita, 2014-Ohio-2540. “R.C. 1303.10(C). The law provides that an instrument payable to an identified person may become payable to bearer if it is indorsed in blank.”
U.S. Bank Nat'l Ass'n v. Courthouse Crossing Acquisitions, LLC, 2017-Ohio-9231, 101 N.E.3d 1243. “" R.C. 1303.10(C). "An instrument, when specially indorsed, becomes payable to the identified person and may be negotiated only by the indorsement of that person.”
In re Moehring, 485 B.R. 571 (Bankr. S.D. Ohio 2013). “. The Debtor's legal counsel filed a motion to withdraw as counsel on March 12, 2012, which the court granted after a hearing on May 4, 2012 (docs.”
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