John writes out a check for $100 on his account at the Sacred Heart Bank to repay the $100 he owes to Perry. He gives the check to Eliot and asks him to hand it over to Perry. However, Eliot loses the check before he can hand it to Perry. Later, John realized that he had not written Perry's name on the lost check. According to the provisions of the UCC, on which of the following parties should the risk of loss of the check be placed?