Pay to the Order of Whom?—The Case of the Ambiguous Multiple Payee Designation

For a variety of reasons, the issuer of an instrument often finds it desirable to make the instrument payable to a multiple payee, either jointly or in the alternative. The article analyzes the ambiguity of the multiple payee issue including historical development and cases which addressed a variety of multiple payee designations. The author also offers a proposed U.C.C. amendment to resolve the dilemma of ambiguous multiple payee designations.