Ohio Revised Code

Ohio Rev. Code § 5808.10 (2026)

Adequate records of administration

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(A) A trustee shall keep adequate records of the administration of the trust.

(B) A trustee shall keep trust property separate from the trustee's own property.

(C) Except as otherwise provided in division (D) of this section and in section 2131.21 of the Revised Code, a trustee not subject to federal or state banking regulation shall cause the trust property to be designated so that the interest of the trust, to the extent feasible, appears in records maintained by a party other than a trustee or beneficiary.

(D) If the trustee maintains records clearly indicating the respective interests, a trustee may invest as a whole the property of two or more separate trusts.

Notes of Decisions
Cited in 4 cases (1 in the last 5 years), 2014–2025 · leading case: State v. Searfoss, 2019-Ohio-4619, 135 N.E.3d 853.
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State v. Searfoss, 2019-Ohio-4619, 135 N.E.3d 853. · cites it 6× “At one point, the state read R.C. 5808.10(B) to the jury, and then asked the jury: “Is there any ambiguity whatsoever in that law? Does it make exceptions, what if’s, if you are on hard times? Absolutely not.”
McHenry v. McHenry, 2017-Ohio-1534. “{¶46} The court’s finding that appellant committed a breach of the trust is not against the manifest weight of the evidence.”
Cartwright v. Batner, 2014-Ohio-2995, 15 N.E.3d 401. “” This statute, however, does not define what constitutes an adequate record. Nonetheless, R.”
Zimmerman v. Dillon, 2025-Ohio-3157. · cites it 2× “Duty to Keep Adequate Records – R.C. 5808.10 {¶26} R.C. 5808.10(A) mandates that a trustee “keep adequate records of the administration of the trust.”
Ohio Rev. Code § 5808.10(A): 2 cases
Cartwright v. Batner, 2014-Ohio-2995, 15 N.E.3d 401. “” This statute, however, does not define what constitutes an adequate record. Nonetheless, R.”
Zimmerman v. Dillon, 2025-Ohio-3157. “Duty to Keep Adequate Records – R.C. 5808.10 {¶26} R.C. 5808.10(A) mandates that a trustee “keep adequate records of the administration of the trust.”
Ohio Rev. Code § 5808.10(B): 2 cases
State v. Searfoss, 2019-Ohio-4619, 135 N.E.3d 853. “At one point, the state read R.C. 5808.10(B) to the jury, and then asked the jury: “Is there any ambiguity whatsoever in that law? Does it make exceptions, what if’s, if you are on hard times? Absolutely not.”
McHenry v. McHenry, 2017-Ohio-1534. “{¶46} The court’s finding that appellant committed a breach of the trust is not against the manifest weight of the evidence.”
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