Delivery was necessary to render a deed effective, both at Common law and under modern statutes. Delivery may be in escrow. A delivery in escrow is one made to a third person who is to hold the deed until a certain act has been done (as for example the payment of the purchase price) and then deliver the deed to the grantee named in the deed.10

10 A more complete treatment of the matters discussed in this chapter will be found under the subject of Abstracts, in this volume.