Ohio Revised Code

Ohio Rev. Code § 1303.21 (2026)

Negotiation - UCC 3-201

✓ current as of May 2026
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(A) "Negotiation" means a voluntary or involuntary transfer of possession of an instrument by a person other than the issuer to a person who by the transfer becomes the holder of the instrument.

(B) Except for negotiation by a remitter, if an instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement by the holder. If an instrument is payable to bearer, it may be negotiated by transfer of possession alone.

Notes of Decisions
Cited in 45 cases (3 in the last 5 years), 1966–2024 · leading case: Whittiker v. Deutsche Bank Nat'l Trust Co., 605 F. Supp. 2d 914 (N.D. Ohio 2009).
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Whittiker v. Deutsche Bank Nat'l Trust Co., 605 F. Supp. 2d 914 (N.D. Ohio 2009). · cites it 8× “The Ohio “Negotiation” Statute, Ohio Rev.Code § 1303.21 The primary focus of plaintiffs’ objections to the Recommendation is that it did not consider the Ohio “negotiation” statute.”
U.S. Bank Natl. Assn. v. Crow, 2016-Ohio-5391. · cites it 2× “See also R.C. 1303.21(B) (“If an instrument is payable to bearer, it may be negotiated by transfer of possession alone.”
U.S. Bank Nat'l Ass'n v. Courthouse Crossing Acquisitions, LLC, 2017-Ohio-9231, 101 N.E.3d 1243. · cites it 3× “" R.C. 1303.21(A). "Except for negotiation by a remitter, if an instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement by the holder.”
HSBC Bank USA, Natl. Assn. v. Surrarrer, 2013-Ohio-5594. · cites it 2× “” R.C. 1303.21(A). “After negotiation, an entity is a holder ‘[i]f the instrument is payable to an identified person [and] the identified person [is] in possession of the instrument[,]’” or, if it is payable to the bearer, anyone in possession.”
Glimcher v. Reinhorn, 587 N.E.2d 462 (Ohio Ct. App. 10th Dist. 1991). · cites it 2× “R.C. 1303.21 provides in pertinent part: “(D) Unless an instrument provides otherwise, interest runs at the rate provided by law for a judgment: “(1) in the case of a maker, acceptor, or other primary obligor of a demand instrument, from the date of demand; “(2) in all other…”
Wells Fargo Bank, N.A. v. Byers, 2014-Ohio-3303. · cites it 2× “The "transfer" of an instrument requires physical delivery of the note "for the purpose of giving to the person receiving delivery the right to enforce the instrument.”
Wiltshire Capital Partners v. Reflections II, Inc., 2020-Ohio-3468, 154 N.E.3d 1036. “An "[i]ndorsement" is "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 [to accomplish] * * * negotiat[ion] [of] the instrument.”
The Bank of New York Mellon v. Lewis, 2014-Ohio-5599. · cites it 3× “” R.C. 1303.21(A). Except in circumstances not applicable here, where “the instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement by the holder.”
Self Help Ventures Fund v. Jones, 2013-Ohio-868. · cites it 2× “” R.C. 1303.21(A). “[I]f an instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement by the holder.”
U.S. Bank Natl. Assn. v. Higgins, 2012-Ohio-4086. · cites it 2× “” R.C. 1303.21(A). “Except for negotiation by a remitter, if an instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement by the holder.”
Fed. Home Loan Mortg. Corp. v. Schwartzwald, 2011-Ohio-2681, 957 N.E.2d 790. · cites it 2× “” R.C. 1303.21(A). “Except for negotiation by a remitter, if an instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement by the holder.”
Fed. Nat'l Mortg. Ass'n v. Herren, 2017-Ohio-8401, 99 N.E.3d 1071. · cites it 2× “" R.C. 1303.21(A). The statute goes on to provide, with limited exception, "if an instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement 3 by the holder.”
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Ohio Rev. Code § 1303.21(A): 24 cases
Bank of Am., N.A. v. Miller, 2011-Ohio-1403, 956 N.E.2d 319.
HSBC Bank USA, Natl. Assn. v. Surrarrer, 2013-Ohio-5594. “” R.C. 1303.21(A). “After negotiation, an entity is a holder ‘[i]f the instrument is payable to an identified person [and] the identified person [is] in possession of the instrument[,]’” or, if it is payable to the bearer, anyone in possession.”
H.S.B.C. Bank U.S.A. v. Brinson, 2018-Ohio-3467, 118 N.E.3d 1140.
HSBC Bank USA v. Brinson, 2023-Ohio-1462, 214 N.E.3d 85.
Deut Sche Bank Trust Co. of Ams. v. Jones, 2018-Ohio-587, 107 N.E.3d 117.
Ohio Rev. Code § 1303.21(B): 23 cases
U.S. Bank Natl. Assn. v. Crow, 2016-Ohio-5391. “See also R.C. 1303.21(B) (“If an instrument is payable to bearer, it may be negotiated by transfer of possession alone.”
Wiltshire Capital Partners v. Reflections II, Inc., 2020-Ohio-3468, 154 N.E.3d 1036. “An "[i]ndorsement" is "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 [to accomplish] * * * negotiat[ion] [of] the instrument.”
U.S. Bank Nat'l Ass'n v. Courthouse Crossing Acquisitions, LLC, 2017-Ohio-9231, 101 N.E.3d 1243. “" R.C. 1303.21(A). "Except for negotiation by a remitter, if an instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement by the holder.”
Nationstar Mtge. L.L.C. v. Payne, 2017-Ohio-513.
The Bank of New York Mellon v. Lewis, 2014-Ohio-5599. “” R.C. 1303.21(A). Except in circumstances not applicable here, where “the instrument is payable to an identified person, negotiation requires transfer of possession of the instrument and its indorsement by the holder.”
Ohio Rev. Code § 1303.21(D): 1 case
Hosford v. Automatic Control Sys., Inc., 470 N.E.2d 263 (Ohio Ct. App. 9th Dist. 1984).
Ohio Rev. Code § 1303.21(D)(1): 1 case
Hosford v. Automatic Control Sys., Inc., 470 N.E.2d 263 (Ohio Ct. App. 9th Dist. 1984).
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