On Aug. 25, the Florida Supreme Court issued an opinion in 1944 Beach Boulevard v. Live Oak Banking, No. SC21-1717 holding that Article 9 of the Florida Uniform Commercial Code (the UCC) is unforgiving with respect to any error in the debtor’s name contained in a UCC-1 financing statement filed with the Florida Secured Transaction Registry (the Registry).

In Florida, perfection of a security interest in personal property occurs when a sufficient UCC-1 financing statement (a UCC-1) is filed with the Registry. The Registry provides an online database that can be searched using a debtor’s name, and the results display an alphabetical name list with 20 entries and the exact or nearest match at the top of the search results screen. The commands “Previous” and “Next” appear on the results screen, allowing the user to navigate forward and backward through all the names and all financing statements in the Registry.