Digital Transformation: eSignature and ePayment News and Trends - September/October 2024

Today’s ever-shifting business environment means that consumers, businesses, employers, and employees all expect to transact digitally. To remain efficient and competitive, companies must digitally transform their businesses. Successful transformation and maintenance require careful planning and up-to-date knowledge to ensure smooth integration with existing business technology, positive customer experience, and ongoing regulatory compliance.

This newsletter includes legal insights and brief summaries of recently enacted federal and state laws, federal and state regulatory activities, fresh judicial precedent, and other important news to keep you up to date in the ever-evolving electronic environment.

If you’d like to discuss one of these items, or a project you’re considering, please reach out to one of the editors – and, if there is a topic you’d like us to cover in a future Insight, we’d love to hear from you.

 

INSIGHTS

Disruption in global financial services: Move fast on compliance, but don’t break anything

By Isabelle Ord, Margo H.K. Tank, and Sam Bodle

As they look to the future, financial services organizations are confronted by significant change, uncertainty, and disruption. Increasing deglobalization, macro-economic headwinds, the rise of big data, AI, and other new technologies, and evolving regulatory guidance are creating increasing pressures – all against the backdrop of transitioning to net zero.

DLA Piper has conducted a survey of the financial services industry to gauge sentiment on three key areas of future disruption: the impact of the ESG agenda, digital transformation, and the role of regulation (on these themes and more broadly). Data was sourced from nearly 800 financial services executives and senior-level decision makers from organizations of all sizes across the globe, and in all major industry subsectors.

The result? The industry understands transformative change is there but, far from being daunted by that prospect, 80 percent of all organizations surveyed are optimistic about the next two years. This is driven by positivity about the product and service opportunities that new technology will bring, and the potential benefits of the ESG agenda. Respondents were, however, pessimistic about the pace and uncertainty of regulation in the coming change. Read more.

 

REGULATORY DEVELOPMENTS

FEDERAL

CFPB

CFPB seeks comment on revisions to remittance transfer rule. On September 20, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule amending Regulation E’s disclosure requirements for international money transfers under the Remittance Transfer Rule. Comments are due November 4. The Electronic Fund Transfer Act and Regulation E require remittance companies to give senders a disclosure at the time of payment, including on a receipt, which must include contact information for both state regulators and the CFPB. If adopted, the proposed rule amendment would clarify that consumers should contact their remittance company for issues specific to their money transfer. 

CFPB finalizes personal financial data rights rule. On October 22, the CFPB announced it finalized a rule under Section 1033 of the Consumer Financial Protection Act designed to “accelerate responsible open banking in the US.” The rule enables consumers to access and share data associated with bank accounts, credit cards, mobile wallets, payment apps, and other financial products, or to authorize a third party to access and share such data, such as transaction information, account balance information, information needed to initiate payments, upcoming bill information, and basic account verification information. According to the rule, financial providers must make this data available without charging fees to the consumer. This rule is designed to move the industry away from current “screen-scraping” practices that involve the consumer providing their account passwords to third parties to access such data. The rule also establishes privacy protections, limiting use of personal financial data only for the purposes requested by the consumer, and prohibiting third parties from using consumer data for other purposes that benefit the third party.

OCC

OCC opposes new Illinois interchange fee law. The Office of the Comptroller of the Currency (OCC) recently filed an amicus brief in a suit for preliminary injunction filed by several banking associations to challenge the Illinois Interchange Fee Prohibition Act (IFPA), which was enacted in June and is set to become effective July 2025. The IFPA would prohibit interchange fees on taxes or gratuities charged by card issuers and other companies involved in processing electronic payments and would restrict companies from using transaction data for any other purpose unless legally required. In its brief, the OCC argues that IFPA would erode the essential infrastructure and result in “extraordinary operational burdens” on national banks “that likely will be passed on to consumers in the form of higher fees, reduced services, and weakened fraud protection.” The OCC also noted that the restrictions in the IFPA will likely result in inconsistent state laws that will undermine national payments systems.

FTC

FTC announces final “click-to-cancel” rule, making it easier for consumers to end recurring subscriptions and memberships. On October 16, the Federal Trade Commission (FTC) announced a final “click-to-cancel” rule that will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign up. Most of the final rule’s provisions will go into effect 180 days after it is published in the Federal Register. For more information, see our alert.

FCC

FCC extends effective dates for TCPA rule amendments. On October 11, the Federal Communications Commission (FCC) announced new effective dates for amendments to rules under the Telephone Consumer Protection Act (TCPA), making it simpler for consumers to revoke consent to unwanted robocalls and robotexts. The amendments include:

• Consumers may revoke consent to robocalls and robotexts “in any reasonable manner,” such as use of the words: stop, quit, end, revoke, opt out, cancel, or unsubscribe.
  
  
• Callers must honor do-not-call and revocation requests “as soon as practicable” and no later than ten business days after the request.
  
  
• Text-senders may send one text message in response to a revocation request confirming or clarifying the scope of the request within five minutes.

The amendments will now take effect on April 11, 2025.

Treasury

Treasury officially withdraws proposed 2020 rule requiring customer identity collection for self-custody wallet users. On August 16, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) officially announced that it had withdrawn a proposed rule under the Bank Secrecy Act (BSA) that would have required financial institutions to collect the identities of customers using self-hosted cryptocurrency wallets. When it was announced in 2020, the proposed rule faced significant backlash from lawmakers and the cryptocurrency industry, who objected that the rule was unworkable and likely to stifle innovation.

Treasury announces plans to revise the definition of “money.” On August 16, the Treasury Department published its Semiannual Regulatory Agenda in which it announced plans to revise the definition of “money” to enhance reporting requirements for cryptocurrency transactions. The change, which is scheduled for September 2025, is intended to align crypto regulations with those for traditional fiat currency. The new definition will cover digital assets with legal tender status, including central bank digital currencies. It will also cover "convertible virtual currencies," which are defined as a medium of exchange that either has an equivalent value as currency or acts as a substitute for currency, but lacks legal tender status.

FDIC

FDIC issues NPRM enhancing recordkeeping for deposits from fintech and nonbanks. The Federal Deposit Insurance Corporation (FDIC) on September 17 announced a notice of proposed rulemaking (NPRM) that would strengthen recordkeeping for bank deposits received from third-party, nonbank companies that accept those deposits on behalf of consumers and businesses. These accounts often involve funds from end users or other third parties that are originated through fintech companies, fintech intermediaries, and nonbank companies, and are held in a single custodial account at a bank.

Under the proposed rule, FDIC-insured banks holding these types of custodial accounts would be required to take certain steps to ensure accurate account records are maintained in order to determine the individual owner of the funds, including a requirement to reconcile the account for each individual owner on a daily basis. According to the FDIC, the NPRM helps “banks know the actual owner of deposits placed in a bank by a third party …, whether the deposit has actually been placed in the banks, and that the banks are able to provide the depositor their funds even if the third party fails.” The NPRM was published in the Federal Register on October 2, and the FDIC is accepting public comments until December 2.

FFIEC

FFIEC updates guidance on financial institutions’ information technology practices. On August 29, the Federal Financial Institutions Examination Council (FFIEC) announced the issuance of a new examiner’s guide to assess financial institutions’ information technology development, acquisition, and maintenance. The Development, Acquisition, and Maintenance booklet is intended to provide examiners with fundamental examination expectations regarding entities’ development and acquisition planning and execution, governance and risk management, and maintenance and change management practices. The booklet discusses the interconnectedness of an entity’s assets and processes and those of its third-party service providers with an eye to compliance with applicable laws and regulations. This booklet replaces the version issued in April 2004.

STATE

Digital assets

California modifies and extends Digital Financial Assets Law. On September 29, California Governor Gavin Newsom signed AB 1934 into law, updating the state’s Digital Financial Assets Law (DFAL) to extend the compliance deadline for digital financial asset businesses and making other modifications to the DFAL. AB 1934 extends the deadline for compliance an additional year to July 1, 2026 and also includes:

• Additional recordkeeping obligations on licensed entities, including monthly compliance reports
  
  
• Permitting covered persons to engage in the exchange, transfer, or storage of stablecoins only if the stablecoin meets certain requirements and is approved by the commissioner
  
  
• Requiring digital asset kiosk operators to ensure that persons engaging in activities on the kiosks hold a valid license

Virtual currency

California court upholds daily transaction limit for crypto kiosks. On September 4, the California Department of Financial Protection and Innovation (DFPI) announced that the Superior Court for Los Angeles County upheld the state Digital Financial Assets Law’s consumer protections for users of crypto asset kiosks, often called “bitcoin ATMs.” The plaintiff alleged that the $1,000 per customer per day crypto kiosk withdrawal limit in the Digital Financial Assets Law was unreasonable and exceeded the authority of the state legislature. According to the legislature and the DFPI, the daily transaction limits at crypto kiosks are designed to prevent fraudulent transactions. The court entered a judgment of dismissal in favor of the DFPI, finding that the transaction limits did not exceed legislative authority, and dismissed the complaint in its entirety with prejudice. The decision has been appealed.

Money transmission

Another state adopts Model Money Transmission Modernization Act. On August 23, New Hampshire adopted HB 1241 based on the 2021 Model Money Transmission Modernization Act (Model Act). The first five sections of the bill became effective October 22 and Section 9 will be effective December 30, 2030. All other sections were effective at the time of enactment. Twenty-one other states have already enacted bills based on the Model Act. For more information on state adoptions of the Model Act, see our April, June, and August issues.

Digital and electronic signatures

California DMV establishes Digital Signature Acceptance Program. On August 28, the State of California Department of Motor Vehicles issued Vehicle Industry News 2024-13, announcing the Digital Signature Acceptance Program (DSAP) for the acceptance of digital signatures by the DMV. The DSAP allows first line service providers to submit approved documents to the DMV electronically with digital signatures and authentication. The notice identifies certain documents that may be submitted bearing electronic signatures and those that require digital signatures.

California enables use of electronic signatures in workers’ compensation. On September 22, California enacted AB 2337 which allows documents that require a signature in connection with the workers’ compensation system to be filed with an “electronic signature” defined as “an electronic sound, symbol, or process attached to or logically associated with an electronic record and executed or adopted by a person with the intent to sign the electronic record, where the electronic signature is attributable to a person.”

Recordation

California enables recordation of electronically signed records. California enacted AB 2004 on September 27 enabling a “disinterested custodian of an electronic record” to certify before a notary public that a tangible copy of the electronic record is a complete and accurate reproduction of the electronic record. The new law also requires county recorders to accept for recording such certified tangible copies of electronic records.

Remote online notarization (RON)

North Carolina clarifies geolocation requirements for RON. On September 9, the North Carolina legislature overrode the veto of the state governor and enacted H 556 which, in part, clarified the geolocation requirements in RON. The new law modifies prior law and now requires that the RON platform geolocate the remotely located principal “when the remotely located principal is conducting the remote electronic notarization via a device capable of identifying the geographic location of the remotely located principal at the time of the remote electronic notarization.” The law further permits the Secretary of State to amend its RON rules to include processes and requirements for the use of geolocation technology in RON “if technology becomes available so that geolocation may be broadly utilized without a global position system.”

INDUSTRY DEVELOPMENTS

ISO publishes standard for mobile driver’s licenses. On October 7, the International Organization for Standardization (ISO) reportedly published ISO/IEC TS 18013-7:2024, which standardizes how the public can use a mobile driver’s license (mDL) to authenticate identity over the internet. This specification details how a relying party can establish a secure connection over the internet with an mDL holder through which they can authenticate identity data shared by the holder. This new standard builds on the capabilities of the mDL previously standardized in ISO/IEC 18013-5.

 

CASE LAW

FEDERAL

Biometrics

Chicago federal judge finds make-up “try on” technology did not capture biometric information. In the case of Castelaz v. Estée Lauder Co., Inc., et al., 2024 US Dist. LEXIS 7321*, USDC Northern Distr. Ill., Jan. 10, 2024, the court granted the defendant’s motion to dismiss for failure to state a claim under the Illinois Biometric Information Privacy Act, 740 Ill. Comp. Stat. 14 /1 et seq. (BIPA), without prejudice, because the plaintiffs’ complaint failed to include any specific factual allegations that the defendants were capable of determining the plaintiffs’ identities through facial scans, whether alone or in conjunction with other methods or sources of information available to the defendants. As defined in Section 14/10 of the BIPA, “biometric information” is information “based on an individual's biometric identifier used to identify an individual." (emphasis added).

AML/BSA

Federal Reserve Board enters into consent order against Texas bank for AML/BSA violations. On September 4, the Federal Reserve Board announced entry of a consent cease-and-desist order with United Texas Bank in connection with an examination of the bank that identified significant deficiencies, including in connection with virtual currency customers relating to anti-money laundering (AML) and Bank Secrecy Act (BSA) violations. In addition to other requirements, the consent order requires the bank to submit revised programs acceptable to the supervisors for BSA/AML compliance, customer due diligence, suspicious activity monitoring and reporting, and Office of Foreign Assets Control (OFAC) compliance.

STATE

Digital identity

North Carolina appeals court bars use of digital IDs for voting. On September 27, the North Carolina Court of Appeals issued an amended order which, by unanimous vote, enjoined the State Board of Elections from accepting the University of North Carolina - Chapel Hill Mobile One Card “or any other image of a photo ID, either as a photocopy or a photo on a mobile device” that is prohibited by the State Board of Election’s Numbered Memo 2023-03 for the purpose of casting a ballot in the November general election. The numbered memo states that “[a]n image of a photo ID, either as a photocopy or a photo on a mobile device is not one of the permitted forms of photo ID when voting in person.” The Mobile One Card is a digital ID kept on a student’s phone or electronic device and is the default ID provided to students upon enrollment. The injunction remains in effect until disposition of the litigation.

Electronic signature and online contract formation

Failure to opt out of arbitration provisions insufficient to constitute agreement to arbitrate. In consolidated actions before the US District Court for the Southern District of California (Pliszka v. Axos Bank, No. 24-cv-445-RSH-SBC, 2024 U.S. Dist. LEXIS 165666 (S.D. Cal. Sep. 13, 2024); Pliszka v. Axos Bank, No. 24-cv-445-RSH-SBC, 2024 U.S. Dist. LEXIS 165666 (S.D. Cal. Sep. 13, 2024)), the plaintiff, in connection with a money market account with Axos Bank d/b/a UFB Direct, received an updated online access agreement and a personal deposit account agreement with revised arbitration provisions and a class action waiver. The plaintiff was notified of the agreements by email and did not opt out of the updated online access agreement within the permitted 30-day window.

In response to Axos Bank’s motion to enforce the arbitration agreement contained in the online access agreement, the court found that, under California contract law, failure to opt out of the updated agreement did not constitute acceptance absent evidence that the plaintiff intended to use silence as acceptance. Therefore, the court found the plaintiff was not bound by the updated arbitration provisions. However, the court noted that the arbitration agreement in the original, un-updated online access agreement delegated decisions regarding enforceability of the arbitration provision to the arbitrator, and so granted the defendant’s motion to determine arbitrability of the dispute under the original terms.

Clicking “submit” held not to constitute consent to arbitration agreement. In Marshall v. Georgetown Memorial Hospital d/b/a Tidelands Health, the US Court of Appeals for the Fourth Circuit affirmed the district court and denied Tideland’s motion to compel arbitration of the plaintiff’s claims resulting from Tidelands’ denial of employment in response to the plaintiff’s 2020 application. The plaintiff had previously applied for (and was denied) employment with Tidelands in 2016 using Tidelands’ online application process. In 2016, the plaintiff was required to provide personal information and directed to read and scroll through Tidelands’ pre-employment statement, which included an agreement to arbitrate. The plaintiff was also required to check a box next to a button titled “I ACCEPT” that was adjacent to the notice: “By checking the box above next to the ‘I ACCEPT’ button, I am … agreeing to the PRE_EMPLOY[ME]NT STATEMENT which contains the Agreement to Arbitrate.” The plaintiff was not hired in 2016.

When the plaintiff again accessed Tidelands’ online application process in 2020, the platform recognized the plaintiff as a returning user. At the top of the webpage was the statement: “ARBITRATION NOTICE: THIS APPLICATION AND APPLICATION PROCESS IS SUBJECT TO ARBITRATION PURSUANT TO THE SOUTH CAROLINA UNIFORM ARBITRATION ACT.” Just below this statement was a “Submit” button that the returning applicant could click to submit their new application. Below this “Submit” button was a current application pre-populated with personal information from the plaintiff’s 2016 application. The returning applicant could make changes to the pre-populated data. If the returning applicant scrolled down the webpage below the personal information fields, the platform displayed the 2016 pre-employment statement containing the arbitration agreement with the “I ACCEPT” checkbox already checked and pre-populated with the date the prior application was submitted. At the very bottom of the webpage was a second “Submit” button that the returning applicant could click to submit their new application. Notably, the plaintiff, as a returning applicant, was not required by the platform to scroll down through the pre-employment statement containing the arbitration agreement before clicking “Submit” to submit a new application.

The district court found that Tidelands had not demonstrated the existence of a binding arbitration agreement in 2020, and the Fourth Circuit reviewed the decision de novo. The Fourth Circuit noted that Tidelands bears the burden of establishing the existence of a binding agreement to arbitrate under South Carolina law and must show that (1) the plaintiff has reasonable notice of an offer to enter into an arbitration agreement and (2) the plaintiff had manifested her assent to that agreement.

With respect to reasonable notice, the Fourth Circuit noted that users of online platforms are not obligated to scroll through all screens of a webpage when the user can complete all their business on the first screen. In this case, the “Submit” button at the top of the webpage enabled the plaintiff to enter all necessary updates and submit her 2020 application without ever scrolling down to the 2016 arbitration agreement. Without any additional information on that first screen, the user is not under constructive or inquiry notice of the arbitration agreement because the offer to enter into a contract was not called to the attention of the user. According to the Fourth Circuit, a party’s duty to read a contract “does not morph into a duty to ferret out contractual provisions when they are contained in inconspicuous hyperlinks or can be found only by scrolling through additional screens.”

The Fourth Circuit further stated that the arbitration notice at the top of the webpage was not enough to put the plaintiff on reasonable notice that there was an offer of an agreement to arbitrate, and the plaintiff should scroll to find it. The arbitration notice neither provided nor referred to the actual terms of the proposed arbitration agreement, and “most clearly” told the plaintiff that the application was “subject to” South Carolina arbitration law – “not that it is subject to contract ‘terms and conditions’ that can be reviewed and agreed to by scrolling down or clicking a hyperlink.” Even if the plaintiff had scrolled down, she would have seen only her 2016 arbitration agreement. The Fourth Circuit concluded that review of the 2016 arbitration agreement did not “clearly and conspicuously” indicate that the plaintiff was being asked to form a new arbitration agreement for the new application.

The Fourth Circuit also found that Tidelands cannot show that the plaintiff manifested assent to its arbitration agreement in 2020. Clicking a “Submit” button at the top of the webpage was not enough to manifest assent as, per the court, the ordinary meaning of “submit” does not manifest assent to an agreement or acceptance of contract terms. “Only if the user is explicitly advised that the act of clicking [a button] will constitute assent to an agreement will it have that effect.” Tidelands’ 2020 returning applicant process did not inform the plaintiff that her conduct – clicking the “Submit” button to enter a job application through the online platform – would constitute assent to an arbitration agreement.

 

DLA Piper news

The Financial Times recognizes DLA Piper as one of the Most Innovative Law Firms in North America. 

Emily Honsa Hicks was recently named to the D.C. Bar Association’s 2023 Capital Pro Bono Honor Roll, among many other DLA Piper attorneys.

 

RECENT EVENTS

On October 15, DLA Piper presented an engaging discussion on the findings from our new global financial services report, Financial Futures: Disruption in US and Global Financial Services. The report identifies and analyzes disruptors in the industry such as AI use, ESG requirements, digitization of financial services, privacy and cyber risks, and key issues that matter to senior leaders of financial institutions and fintechs. The report findings are based on nearly 800 surveyed decision makers in the global financial services sector. Key insights include the following:

• More than 70 percent of respondents across the global sector believe that digitalization will have a transformative effect on financial services over the next two years, and more than 86 percent believe the same about AI
  
  
• More than 80 percent of financial services organizations believe that it is “the new normal” for ESG concerns to be a core driver of the industry, and
  
  
• Half of respondents stated that the greatest impact on their businesses over the past two years has been managing risks related to cybersecurity and financial crime, and more than half (57 percent) expect this issue to affect them in the immediate future.

The discussion included a keynote from Ambassador Marc Grossman on “Geopolitics, the Global Economy, and Driving Change.” Ambassador Grossman served as US Ambassador to Turkey, Assistant Secretary of State for European Affairs, and Under Secretary of State for Political Affairs. He was most recently the US Special Representative for Afghanistan and Pakistan and is currently a Vice Chairman of The Cohen Group, a business strategic advisory firm headed by former US Secretary of Defense William Cohen and a Vice Chair of the German Marshall Fund board of trustees.

On September 25, DLA Piper presented its webinar focused on IP issues related to international expansion in the Global Expansion and Operation series. It featured Victoria Lee, Co-Chair of the Technology and Life Sciences Licensing and Commercial Transactions group, and Tim O’Leary, the former Vice President Worldwide Commercial Legal at NetApp.

David Whitaker and Emily Honsa Hicks spoke at The Conference on Consumer Finance Law’s Spring Consumer Financial Services Conference on May 30-31 at Loyola University Chicago School of Law.

RECENT PUBLICATIONS

As discussed in “Recent Events” above, DLA Piper published its global financial services report, Financial Futures: Disruption in US and Global Financial Services, after asking nearly 800 financial services decision makers around the world about key disruptors impacting senior leaders in financial institutions and fintechs. Check out our report and read about the challenges and opportunities that AI, digitization, and ESG pose for the financial services industry.

DLA Piper’s Tech Index 2024: Riding the next big wave: Is the tech industry buoyant or sinking? Our Tech Index 2024 explores this topic and more, drawing insights from 1,200 industry leaders and policymakers across the world. While our previous editions focused primarily on Europe, we have expanded the scope of this year’s Index to include all major regions, offering a more comprehensive view of the sector’s growth prospects, anticipated challenges, and emerging opportunities. Some key insights include the following:

• 63 percent of respondents view AI as the most important frontier for growth. Yet, AI adoption is not being driven by CEOs.
  
  
• 50 percent report that ESG is more of a priority now than in 2022. However, 61 percent do not have a comprehensive ESG framework – or any framework at all.
  
  
• 98 percent see opportunities in data monetization. But only 38 percent employ data scientists to harness these opportunities.

Margo Tank and David Whitaker co-authored The Law of Electronic Signatures, 2024 Edition (Thomson Reuters), an essential guide to electronic signatures and records laws, including the context in which the laws were adopted and the ways in which the authors believe the drafters intended them to be interpreted. The authors have more than 30 years combined experience, including involvement with the drafting and passage of the Electronic Signatures in Global and National Commerce Act (ESIGN), the preparation of the Uniform Electronic Transactions Act (UETA), the creation of the Standards and Procedures for electronic Records and Signatures (SPeRS™), and serving as counsel to the Electronic Signatures and Records Association. The insights they provide will be indispensable to anyone seeking to understand the impact of, and the liability associated with, using electronic signatures and electronic records.

These insights include:

• Details on the legal requirements for using electronic signatures and records, including delivery, presentation, signing, and record retention
  
  
• Comprehensive tables itemizing the state variations to the uniform UETA language
  
  
• Special considerations for using electronic signatures and records in connection with emerging and evolving technology
  
  
• Using electronic records and signatures in specialized transactions and documents, such as securities, chattel paper, and mortgages
  
  
• Analysis of the interplay between ESIGN, UETA, and many other key laws and regulations
  
  
• Identification and summaries of recent legal developments and court cases impacting electronic signatures and records

David Stier, Emily Honsa Hicks, and Eric Hall co-authored the chapter on AML, know-your-customer guidelines, and the Bank Secrecy Act and provided general editorial assistance on other chapters in the newly published book, Banking [on] Blockchain: A Legal and Regulatory Primer, published by the American Bar Association. The book is a comprehensive guide to the legal and regulatory landscape surrounding the use of blockchain technology, decentralization, and digital assets within the financial services industry. It also explores the potential benefits and challenges of using these technologies and offers guidance on how financial institutions can navigate the complex regulatory environment.

Emily Honsa Hicks co-authored the “Electronic Signatures and Records” chapter in the Consumer Financial Services Answer Book, 2024 Edition, published by Practicing Law Institute.

Cryptocurrency and Digital Asset Regulation, published by the American Bar Association and co-edited by Deborah Meshulam and Michael Fluhr, includes chapters by Meshulam and Fluhr as well as by Margo Tank.

The MBA Compliance Essentials Remote Online Notarization State Surveys, developed by Liz Caires and Margo Tank, provides a comprehensive look at RON requirements in each state that has enacted RON legislation. These fully editable surveys are organized by category of requirements, including registration, technology, seal and signature, certificates of RON acts, journal, authentication, session, recording, and additional requirements. Companies can purchase the full package, which includes surveys for all states that have enacted RON legislation along with a matrix summarizing state requirements – otherwise, companies can purchase information about individual states as needed.

 

Read

Minimizing AI risk - Top points for compliance officers

California implements new AI and software regulations for insurers

California enacts sweeping new AI regulation

National security risks headline new AML requirements for investment advisers – and more to come?

 

Listen

Navigating the impact of AI in the financial services sector

 

In case you missed it

Read the latest issue of our bulletin Blockchain and Digital Assets News and Trends

Read the latest issue of our bulletin Bank Regulatory News and Trends

 

Contacts

Learn more about our eSignatures and ePayments practice by contacting:

Margo H.K. Tank

David Whitaker

Liz Caires

Emily Honsa Hicks

The editors send their thanks and appreciation to Marc Aronson and Raymond Janicko for their contributions to this and prior issues.