In Master Chemical Corp. v. Inkrott (1990), 55 Ohio St.3d 23, 563 N.E.2d 26, Master Chemical's controller took checks made payable to defendant-bank (Toledo Trust), altered the amounts, and deposited them into an account he had established under an assumed name. Id. at 23-24. Essentially, Toledo Trust had permitted the employee, who it knew to be a fiduciary of Master Chemical, to deposit the funds in a different account that was under the employee's control, rather than placing the checks within Toledo Trust's custody. Master Chemical sued Toledo Trust alleging wrongful payment of a check deposited. Id. at 23. The Ohio Supreme Court agreed with the Court of Appeals that the checks were not properly payable because Toledo Trust had not paid the named payee, citing the rule that checks that are made payable to banks are not bearer paper and a bank treating it as such does so at its own peril. Id. at 25.