Ohio Rev. Code » Chapter 1303
Ohio Revised Code

Ohio Rev. Code § 1303.25 (2026)

Special indorsement - blank indorsement - anomalous indorsement - UCC 3-205

✓ current as of May 2026
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Effective:
August 19, 1994
Latest Legislation:
Senate Bill 147 - 120th General Assembly
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(A) A "special indorsement" means an indorsement that is made by the holder of an instrument, whether payable to an identified person or payable to the bearer, and that identifies a person to whom it makes the instrument payble. An instrument, when specially indorsed, becomes payable to the identified person and may be negotiated only by the indorsement of that person. Section 1303.08 of the Revised Code applies to special indorsements.

(B) "Blank indorsement" means an indorsement that is made by the holder of the instrument and that is not a special indorsement. When an instrument is indorsed in blank, the 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.
Notes of Decisions
Cited in 101 cases (12 in the last 5 years), 1952–2026 · leading case: Fifth Third Mtge. Co. v. Bell, 2013 Ohio 3678 (Ohio Ct. App. 2013).
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Fifth Third Mtge. Co. v. Bell, 2013 Ohio 3678 (Ohio Ct. App. 2013). · cites it 5× “R.C. 1303.25(A). -3- Madison CA2013-02-003 appeals the trial court's decision, raising three assignments of error for review.”
Nationstar Mtge. L.L.C. v. Payne, 2017 Ohio 513 (Ohio Ct. App. 2017). · cites it 3× “R.C. 1303.25(A) and (B). "When an instrument is indorsed in blank, the instrument becomes payable to bearer and may be negotiated by transfer of possession alone until specially indorsed.”
Bank of Am., N.A. v. Pasqualone, 2013 Ohio 5795 (Ohio Ct. App. 2013). · cites it 3× “This constitutes a "special indorsement" under R.C. 1303.25(A). "An instrument, when specially indorsed, becomes payable to the identified person.”
JPMorgan Chase Bank, Natl. Assn. v. Fallon, 2014 Ohio 525 (Ohio Ct. App. 2014). · cites it 6× “R.C. § 1303.25(A). 4 The Fallons argue in their merit brief that the second, undated endorsement is actually a specific endorsement to Flagstar; as opposed to a blank endorsement.”
Bank of New York Mellon v. Fisher, 2020 Ohio 4742 (Ohio Ct. App. 2020). · cites it 4× “R.C. 1303.25(A). “An instrument, when specially indorsed, becomes payable to the identified person and may be negotiated only by the indorsement of that person.”
Deutsche Bank Natl. Trust Co. v. Najar, 2013 Ohio 1657 (Ohio Ct. App. 2013). “By virtue of its possession of the note endorsed in blank and the assignment of mortgage from Argent, Deutsche Bank argued that it was the holder of the note and mortgage, entitled to enforce the note and mortgage, due to the borrowers’ default.”
HSBC Mtge. Servs., Inc. v. Watson, 2015 Ohio 221 (Ohio Ct. App. 2015). · cites it 3× ““When an instrument is indorsed in blank, the instrument becomes payable to bearer and may be negotiated by transfer of 3 A “special indorsement” is “an indorsement that is made by the holder of an instrument * * * and that identifies a person to whom it makes the instrument…”
Bayview Loan Servicing, L.L.C. v. St. Cyr, 2017 Ohio 2758 (Ohio Ct. App. 2017). “R.C. 1303.25(B). {¶ 39} Here, Bayview attached the note endorsed in blank, as well as a copy of the assignments of mortgage to Bayview, to its complaint and the affidavit of Randall Jackson in its motion for summary judgment.”
In Re Smoak, 461 B.R. 510 (Bankr. S.D. Ohio 2011). · cites it 2× “” Ohio Revised Code § 1303.25(A). See also Ohio Revised Code § 1303.”
CitiMortgage, Inc. v. Patterson, 2012 Ohio 5894 (Ohio Ct. App. 2012). “As such, we conclude that CitiMortgage’s complaint Pursuant to R.C. 1303.25(B) a “‘[b]lank indorsement’ means an instrument that is made by 5 the holder of the instrument and that is not a special indorsement.”
U.S. Bank Nat'l Ass'n v. Marcino, 908 N.E.2d 1032 (Ohio Ct. App. 2009). “*337 {¶ 50} R.C. 1303.25(B) states: “ ‘Blank indorsement’ means an indorsement that is made by the holder of the instrument and that is not a special indorsement.”
Bank of Am., N.A. v. Loya, 2014 Ohio 2750 (Ohio Ct. App. 2014). · cites it 2× “26888, 2014- Ohio-1393, ¶ 8. {¶9} Bank of America filed two affidavits in support of its motion for summary judgment.”
Show all 101 citing cases →
— Ohio Rev. Code § 1303.25(A) — 24 cases
Bank of Am., N.A. v. Pasqualone, 2013 Ohio 5795 (Ohio Ct. App. 2013). “This constitutes a "special indorsement" under R.C. 1303.25(A). "An instrument, when specially indorsed, becomes payable to the identified person.”
Fifth Third Mtge. Co. v. Bell, 2013 Ohio 3678 (Ohio Ct. App. 2013). “R.C. 1303.25(A). -3- Madison CA2013-02-003 appeals the trial court's decision, raising three assignments of error for review.”
Nationstar Mtge. L.L.C. v. Payne, 2017 Ohio 513 (Ohio Ct. App. 2017). “R.C. 1303.25(A) and (B). "When an instrument is indorsed in blank, the instrument becomes payable to bearer and may be negotiated by transfer of possession alone until specially indorsed.”
Bank of New York Mellon v. Fisher, 2020 Ohio 4742 (Ohio Ct. App. 2020). “R.C. 1303.25(A). “An instrument, when specially indorsed, becomes payable to the identified person and may be negotiated only by the indorsement of that person.”
In Re Smoak, 461 B.R. 510 (Bankr. S.D. Ohio 2011). “” Ohio Revised Code § 1303.25(A). See also Ohio Revised Code § 1303.”
— Ohio Rev. Code § 1303.25(B) — 87 cases
Fifth Third Mtge. Co. v. Bell, 2013 Ohio 3678 (Ohio Ct. App. 2013). “R.C. 1303.25(A). -3- Madison CA2013-02-003 appeals the trial court's decision, raising three assignments of error for review.”
Nationstar Mtge. L.L.C. v. Payne, 2017 Ohio 513 (Ohio Ct. App. 2017). “R.C. 1303.25(A) and (B). "When an instrument is indorsed in blank, the instrument becomes payable to bearer and may be negotiated by transfer of possession alone until specially indorsed.”
Deutsche Bank Natl. Trust Co. v. Najar, 2013 Ohio 1657 (Ohio Ct. App. 2013). “By virtue of its possession of the note endorsed in blank and the assignment of mortgage from Argent, Deutsche Bank argued that it was the holder of the note and mortgage, entitled to enforce the note and mortgage, due to the borrowers’ default.”
Bayview Loan Servicing, L.L.C. v. St. Cyr, 2017 Ohio 2758 (Ohio Ct. App. 2017). “R.C. 1303.25(B). {¶ 39} Here, Bayview attached the note endorsed in blank, as well as a copy of the assignments of mortgage to Bayview, to its complaint and the affidavit of Randall Jackson in its motion for summary judgment.”
JPMorgan Chase Bank, Natl. Assn. v. Fallon, 2014 Ohio 525 (Ohio Ct. App. 2014). “R.C. § 1303.25(A). 4 The Fallons argue in their merit brief that the second, undated endorsement is actually a specific endorsement to Flagstar; as opposed to a blank endorsement.”
— Ohio Rev. Code § 1303.25(C) — 3 cases
Bank of Am., N.A. v. Loya, 2014 Ohio 2750 (Ohio Ct. App. 2014). “26888, 2014- Ohio-1393, ¶ 8. {¶9} Bank of America filed two affidavits in support of its motion for summary judgment.”
U.S. Bank v. Petrarca, 2026 Ohio 293 (Ohio Ct. App. 2026).
MidFirst Bank v. Spencer, 2020 Ohio 106 (Ohio Ct. App. 2020).
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