An indorsement without recourse has been held not to be a complete contract.1 Hence, an oral contract relieving the indorser for liability even for forgery is enforceable.2 In other jurisdictions an indorsement "without recourse" constitutes a complete contract, and an oral guaranty cannot be shown.3 Under either theory an oral agreement that an indorsement without recourse should have the legal effect of an unconditional indorsement contradicts the terms of the writing and is unenforceable.4