Wis. Stat. » CHAPTER 403 — UNIFORM COMMERCIAL CODE — NEGOTIABLE INSTRUMENTS

Wis. Stat. § 403.205

Special endorsement; blank endorsement; anomalous endorsement

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403.205403.205 Special endorsement; blank endorsement; anomalous endorsement.
403.205(1)(1) If an endorsement is made by the holder of an instrument, whether payable to an identified person or payable to bearer, and the endorsement identifies a person to whom it makes the instrument payable, it is a special endorsement. If specially endorsed, an instrument becomes payable to the identified person and may be negotiated only by the endorsement of that person. The principles stated in s. 403.110 apply to special endorsements.
403.205(2)(2) If an endorsement is made by the holder of an instrument and it is not a special endorsement, it is a blank endorsement. If endorsed in blank, an instrument becomes payable to bearer and may be negotiated by transfer of possession alone until specially endorsed.
403.205(3)(3) The holder may convert a blank endorsement that consists only of a signature into a special endorsement by writing, above the signature of the endorser, words identifying the person to whom the instrument is made payable.
403.205(4)(4) “Anomalous endorsement” means an endorsement made by a person who is not the holder of the instrument. An anomalous endorsement does not affect the manner in which the instrument may be negotiated.
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403.205 HistoryHistory: 1995 a. 449.
403.205 AnnotationWhen the plaintiff was the bearer of a note that was endorsed in blank, the note was payable to the plaintiff under sub. (2). PNC Bank, N.A. v. Bierbrauer, 2013 WI App 11, 346 Wis. 2d 1, 827 N.W.2d 124, 12-0456.
403.205 AnnotationUnder sub. (2), a note endorsed in blank is payable to the bearer and is negotiated by transfer of possession alone. A plaintiff may not enforce a note endorsed in blank that is in the possession of another, including the entity that services the loan for the plaintiff. Bank of New York Mellon v. Klomsten, 2018 WI App 25, 381 Wis. 2d 218, 911 N.W.2d 364, 17-0405.
Notes of Decisions
Cited in 9 cases (1 in the last 5 years), 1980–2025 · leading case: Deutsche Bank National Trust Company v. Thomas P. Wuensch
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Deutsche Bank National Trust Company v. Thomas P. Wuensch (2018) wis · cites it 7× “"10 Wis. Stat. § 403.205 (2); Bierbrauer, 346 Wis.”
PNC Bank, N.A. v. Bierbrauer (2012) wisctapp · cites it 3× “]" Wis. Stat. § 403.205 (2). It is undisputed that PNC is the bearer of the note, and that the note was endorsed in blank.”
Dow Family, LLC v. PHH Mortgage Corp. (2013) wisctapp · cites it 4× “See Wis. Stat. § 403.205 (2). Consequently, PHH argues that "the moment [it] took physical possession of the Note endorsed in blank, it became the bearer of the Note, the holder[ 5 ] of the Note, and was entitled to enforce the Note.”
Bank of America v. Neis (2013) wisctapp · cites it 2× “" Wis. Stat. § 403.205 (2); see also PNC Bank, 346 Wis.”
Rinaldi v. HSBC Bank USA, N.A. (2013) wieb · cites it 2× “See Wis. Stat. §§ 403.205 ; 403.301. The Debtors complain about the apparent lack of the endorsement in the state court foreclosure; but the state court was the forum to raise that argument.”
Schmid v. Bank of America, N.A. (In re Schmid) (2013) wiwb · cites it 2× “Wis. Stat. § 403.205 (2). BANA is in possession of the Note.”
Northwestern National Insurance Co. of Milwaukee v. Midland National Bank (1980) wis “” 16 The scope of a restrictive indorsement is defined in sec. 403.205, Stats.: “403.206. Restrictive indorsements.”
Cerny v. Old National Bank (2025) wiwb · cites it 2× “109 (3), an instrument payable to an identified person becomes payable to the bearer if it is endorsed in blank under Wis. Stat. § 403.205 (2). The state court made a specific finding that Old National was the successor-by-merger to AnchorBank and so was the secured party…”
U.S. Bank, Nat'l Ass'n v. Emery (2019) wisctapp “§ 403.205(2) ). ¶14 Here, on its face, the endorsement is a Countrywide endorsement signed by a Countrywide employee, and Emery concedes that the presumption of validity found in WIS.”
— Wis. Stat. § 403.205(2) — 2 cases
PNC Bank, N.A. v. Bierbrauer (2012) wisctapp “]" Wis. Stat. § 403.205 (2). It is undisputed that PNC is the bearer of the note, and that the note was endorsed in blank.”
U.S. Bank, Nat'l Ass'n v. Emery (2019) wisctapp “§ 403.205(2) ). ¶14 Here, on its face, the endorsement is a Countrywide endorsement signed by a Countrywide employee, and Emery concedes that the presumption of validity found in WIS.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.