Sticking With a Manual Signature Process: Don’t Laugh

Following up my recent e-signature blog with something light here. You waited twenty years. Twenty years since Congress enacted the E-Sign Act - and then you found out that the relief in that law didn't apply to the SEC. So you endured the pain of maintaining a manual signature process for lo, all these many years. Yeah, I call it a "manual" signature process. Some like to refer to them as "wet" signatures. To me, that feels too much like something out of "Beach Blanket Bingo." The classic beach movie from 1965 with Frankie and Annette. Some companies may well have found that their existing disclosure controls and collection processes work just fine. They like their manual signatures. That's totally acceptable. The SEC's rule changes from 2020 don't mandate e-signatures. They just permit them if that's a direction you want to go. My guess is that many companies have found that a hybrid of both manual and electronic signatures is preferable. That obviously creates a bit more work in terms of developing processes and building out your disclosure controls. But a patchwork might be the best you can pull off realistically. For reasons I'll explain soon enough...