E-Signature Eligible Documents - NFS (Brokerage Accounts)
National Financial has the following policy on Accepting Electronic Signatures
Effective July 31, 2012, National Financial will accept electronic signatures (e-Signatures) on NFS-required documents, with certain noted conditions as described below.
Signature Acceptability Criteria
After careful consideration of operational requirements and of the variety of e- Signature options available in the market, National Financial has determined that the following criteria must be met, in order for National Financial to accept the electronic signature on an NFS-required document:
The signature must appear on the signature line of the form
The signature must visually display either:
the client's hand-drawn, manual signature; OR
the client’s name presented in a legible font
The date of the signature must be displayed with the client’s signature
If multiple parties’ signatures are required on a single form, all signatures must appear on the same signature page.
For further clarity: electronic signatures must meet the above-noted criteria in order to be accepted; National Financial will NOT accept any other electronic records, marks, or files as evidence of an electronic signature, including (but not limited to ) the following examples:
The signature may not be an audio file attached to the document
The signature may not be solely represented by a separate "click-stream report" or other separate document denoting a client's agreement/acknowledgement
The signature may not be solely represented by a code, symbol, or picture on the signature line
Impacted Forms
All NFS-required forms that are currently accepted by NFS in electronic image format (i.e., those for which originals are not required), will be accepted with e-Signatures.
Exceptions
The following notable exceptions will not be accepted:
Check-writing signature cards are designed for signature-comparison purposes and must therefore reflect the client’s actual, physical signature. Thus, only hand-drawn, manual signatures should be used here. Signature cards that contain signatures not reflecting the client’s actual physical signature present the strong risk of client checks failing a signature comparison.
Transfer of Assets (TOA) forms may be subject to review and approval by the delivering firm. Therefore, TOA forms that have been e-Signed may or may not be accepted by the delivering firm. Correspondents who submit e-Signed TOA forms run the risk of potential rejection of the transfer request. Note: currently, e-Signature eligible transfers are typically those initiated with ACAT participant firms, certain mutual fund companies (with whom NFS has agreements), and most transfer agents.