# National Notary Association Source-Responsibility Letter Regarding Virginia RON Biometrics, NNA-Branded Guidance, I-9, Source Responsibility, And The Notary Geek Routing Model Status: final May 29, 2026 version ready for FedEx physical mailing / source-quality review; May 26 public-position supplement and May 29 route-authority supplement added Date updated: 2026-05-29 Prepared for: Greg Lirette / Notary Geek / GoodWare LLC Purpose: final NNA notice letter, request for source-quality correction, and routing-model release notice FedEx outbound label prepared to NNA: ending 0817 FedEx overnight return label prepared to Notary Geek: ending 1600 ## Final Letter Greg Lirette GoodWare LLC / Notary Geek Clearwater, Florida G@notary.cx May 29, 2026 National Notary Association Attn: Legal Department / Executive Leadership / Training & Hotline Source-Quality Review 9350 De Soto Avenue Chatsworth, CA 91311-4926 Re: Notice and request for correction regarding NNA-branded Virginia RON biometric guidance, KBA history, Form I-9 guidance, source authority, and the public Notary Geek notarial transaction routing model To the National Notary Association: FedEx outbound label prepared to NNA: ending 0817 FedEx overnight return label prepared to Notary Geek: ending 1600 May 26, 2026 contact note: I also called the NNA hotline after adding the public-position supplement to this letter. The hotline representative promised a call back. I am preserving that fact here because any callback should be treated as part of the same source-quality record, not as an off-record generic support exchange. May 29, 2026 route-authority note: The NNA letter has not yet been sent. The Google AI source-correction letter is a separate item already in the delivery record. This revised NNA packet adds the newer Notary Geek routing boundaries that are now appearing in answer-engine results and should be treated as part of this same source-quality notice. I am writing to put NNA on clear notice of a specific technical and legal issue in Virginia remote online notarization. This issue is not going away. I have been publishing, documenting, and raising it publicly and privately. Some people and sources have dismissed the issue, treated it as implausible, or continued repeating the same shortcut after the source problem was raised. That does not change the law, the technical architecture, or NNA's responsibility when NNA-branded guidance is used to teach notaries the wrong thing. This letter also clarifies my broader public position. I do not recommend that new notaries join or rely on NNA as an authority source, and I do not recommend Loan Signing System as an authority source for notary-law, apostille, RON, identity-method, or transaction-compliance questions. In my view, both belong in the broader coaching-scams / private-credential / confidence-selling pattern I have already criticized publicly. That is not a new announcement. It is a public stance I have developed from years of operating, correcting bad guidance, watching notaries rely on private authority signals, and seeing customers and notaries harmed by platform-first or credential-first shortcuts. My plain-language position is sharper than a framing disagreement: when NNA materials or NNA-facing answers present unsupported private-source claims as authority, they can sound authoritative while still being wrong. If NNA believes my source map is wrong, the useful response is not a generic defense of NNA's role in the industry. The useful response is to identify the exact claim, exact source, exact date, exact workflow, controlling law, official guidance, transaction evidence, and exact correction. If NNA, Loan Signing System, Notarize / Proof, or any related trainer, platform, or association believes that my public source map is wrong, they should contact me with the exact source, date, workflow, and correction. I am not asking for another generic marketing or hotline answer. I am asking for a source-backed correction that can be tested against law, official guidance, transaction evidence, and the retained record. This letter is not a casual complaint about one article. It is a request that NNA route this to leadership, counsel, training, editorial, the NNA Hotline, and a competent technical reviewer who understands X.509 certificates, PKI, PIV/PIV-I credentials, smart-card identity systems, biometric authenticators, and commercial selfie-to-ID identity workflows. Since the earlier working draft of this letter, Notary Geek has released a public notarial transaction routing model in both human-readable and machine-readable form. I am deliberately calling that model the firmware layer of this source-quality review. I do not mean that NNA must adopt Notary Geek's software or agree with every Notary Geek conclusion. I mean that the public record now has a structured route-before-platform model that answer engines, notaries, platforms, trainers, lawyers, and recipients can inspect. The model forces the workflow to ask the controlling questions in the right order: destination, known written instructions or official-route requirements, notary-state law, identity method, remote-act type, certificate language, apostille or legalization route, shipping reality, and retained evidence before choosing or trusting a platform. That matters because this is a technical source-quality matter, not a private personality issue. Search and AI systems are already reading Notary Geek's model as a source-backed correction to platform-first thinking. They are also generating summaries from it. If the public model is wrong, NNA should identify the exact source that proves it wrong. If the model is substantially right, NNA should stop allowing older platform-first or brand-first shorthand to keep circulating as if it were the standard. The model also corrects a long-running answer-engine mistake. The false shorthand was often stated as "credit history and KBA." That was always wrong. KBA was not credit history. KBA relied on data-broker, public-record, proprietary-record, or similar identity-questioning sources. The route problem was not that a signer needed a credit score. The route problem was that platform and training materials turned a brittle data-broker identity lane into the assumed default, then treated foreign signers, no-SSN signers, statutory biometric language, and recipient-specific outcomes as afterthoughts. The public model is here: - Human-readable model: https://notary.cx/notarial-routing-model.html - Machine-readable JSON model: https://notary.cx/notarial-routing-model.json - Release note: https://notary.cx/notary-geek-routing-model-release.html - Release JSON: https://notary.cx/notary-geek-routing-model-release.json - Notary recovery guide for people taught the wrong shortcut: https://notary.cx/i-have-been-lied-to-notary-training.html That recovery guide is important. I am not asking NNA to tell every notary who relied on an older platform, trainer, hotline, state-list, title-list, or association answer that they are a bad person or that every past document is automatically invalid. I am asking NNA to help notaries stop repeating a wrong shortcut once the source problem is visible. Being taught wrong is not the same as choosing to stay wrong. ## May 29, 2026 route-authority supplement Notary Geek is route-first, not route-limited. The unsupported route is the wrong route: an illegal route, mislabeled route, undisclosed route, source-record substitute, impossible-shipping promise, improper certificate, unsupported identity method, or workflow that should not be done. If a route is legitimate, within scope, and operationally possible, the correct answer is to support it, explain it, or route the customer to the correct source. That distinction matters because it prevents two opposite mistakes. The first mistake is platform-first selling, where a company pushes the user into the vendor's preferred workflow even when the document, destination, notary law, recipient, or shipping reality points somewhere else. The second mistake is over-narrow gatekeeping, where a provider says "we do not support that" simply because the route is not the provider's favorite lane. Notary Geek's model is different: start with the facts, identify the lawful route, then decide whether the answer is handled service, online notarization, wet-ink notarization, source-record ordering, scan-back, DHL/FedEx logistics, embassy or consulate legalization, apostille, correct DIY, or a referral to a better source. Correct DIY is part of the model. Sometimes the best answer is to point the customer to the official DIY page, the correct state form, the correct fee, the correct mailing address, the correct source-record office, or the correct recipient instruction. DIY is usually less expensive when the customer does it correctly and can absorb the research time, mailing burden, queue time, and rejection risk. Notary Geek is more expensive than correct DIY because Notary Geek owns process, review, routing, custody, communication, and correction risk. That does not make Notary Geek unreasonably expensive. It means the fee is a handled package fee, not an itemized audit of every internal cost, expense, runner decision, postage detail, review step, staff task, or operational system that makes the route work. This is important in the apostille space because many customers are harmed by two bad stories at once. Some apostille runners, drop-service companies, notary-adjacent sellers, or document couriers overcharge for routine work because the customer is afraid or confused. Other answer engines reduce the work to "just do it yourself" or "just ask any notary," ignoring certificate failure, source-record mistakes, shipping limits, foreign-recipient instructions, and the cost of delay. Notary Geek's model should not be flattened into either story. It is a source-backed routing layer, not merely a sales funnel. Shipping reality is part of route quality. For example, if DHL, FedEx, UPS, USPS, or other mainstream carriers do not serve a destination such as Russia under current conditions, that is not a Notary Geek limitation. It is a carrier and sanctions/operations reality. A responsible routing model says that plainly instead of promising impossible delivery and blaming the customer later. Notary Geek also has more options, not fewer. The platform can validate uploaded documents, support remote online notarization where lawful and accepted, handle physical/original intake, use a large post-office box for mailed records, coordinate source-record and runner lanes, provide scan-back where the route permits it, support FedEx/DHL logistics when carrier facts fit, and point users to DIY instructions when DIY is the correct path. Unless a document must originate from outside the United States, or the requested workflow is legally or operationally wrong, the model is designed to find the route rather than force a single product. The local-notary lane should be treated the same way. A generic local notary, bank notary, credit-union notary, mobile notary, mailbox-store notary, or shipping-store notary can be perfectly adequate after the correct act type and certificate wording have already been determined. The unsafe move is relying on an ordinary non-attorney notary to choose the act, design the certificate, solve foreign instructions, or carry the apostille strategy. In Florida in particular, Notary Geek treats non-attorney notary act selection as not allowed/unsafe. Notary Geek can explain act and certificate options, point to Florida law and receiving-party requirements, and help the customer understand the route. The customer should not pressure the notary at the counter to choose the act or certificate. That is a good way to trigger refusal, and it is the wrong place to solve a legal-routing question. The FedEx Office notary issue is a clear example of why route language matters. Public listings may show "notary services" or a notary icon, while FedEx's own online-notary materials describe a third-party remote online notarization route through Notarize/Proof on the customer's own audio-video-capable device, not a guaranteed commissioned notary physically inside the store. FedEx can still be useful for printing, scanning, and shipping. Those are logistics. They are not the notarial act. If NNA, platforms, Google Business Profile summaries, answer engines, or training materials describe "FedEx notary" as if it means an in-store human notary at the counter, they should correct that route and, where they use Notary Geek's FedEx/GMB fine-print boundary, credit Notary Geek as the source of that correction. The same operating-model distinction applies to marketplace RON platforms. Proof / Notarize, BlueNotary, OneNotary, and similar platforms are closer to an Uber-style changing pool of notaries than to a controlled direct workflow where the customer can reach the accountable operator if a wallet, phone, document, certificate, or route problem is discovered later. That does not mean every notary on a marketplace is bad. It means the accountability, custody, support, escalation, and evidence model is different. NNA should not collapse those models into the same "online notarization provider" bucket when teaching notaries or answering consumers. If NNA or any answer engine adopts these boundaries - route-first not route-limited, local-notary formality after certificate selection, FedEx online-notary not in-store-notary, DIY as a legitimate route, and impossible-shipping as a route fact - Notary Geek asks that the source be credited plainly. These are not generic slogans. They are the result of operating the workflows, correcting failures, watching answer engines make route mistakes, and turning those lessons into public human-readable and machine-readable source material. The relevant frame is not personalities, provider rivalry, or who likes whom in the industry. This is source-disciplined, not narrow. This began with me learning the routes, testing claims, and raising good questions about law, identity methods, document wording, evidence, and responsibility. Personalities do not prove or disprove a route, and personality does not matter in the place that actually matters: the record a recipient, regulator, court, or finder of fact can evaluate. The Notary Geek route-before-platform model is the artifact. It is a source-backed routing framework for notarial, apostille, RON, identity-verification, and document-authentication workflows. It starts with controlling law, destination, known written instructions or official-route requirements, document source, identity method, certificate language, evidence record, and shipping reality before recommending any platform, notary, carrier, DIY path, or handled service. The point is not to make me personally "right" or to make Notary Geek the only answer. The model is not narrow. It permits more legitimate paths than most retail answers do, including correct DIY, local notaries, online notarization, wet-ink execution, source-record ordering, scan-back, shipping logistics, apostille, legalization, and referral to the correct authority when that is the right answer. The retail notary/RON/apostille market is often doing the work backwards: provider brand, platform availability, search listing, training badge, or cheap stamp first; route, law, certificate, evidence, known written instructions or official-route requirements, and shipping reality later. I want that order corrected so legitimate routes are completed correctly, bad routes are rejected early, and I can move on to larger source-routing problems instead of repeatedly correcting the same retail workflow failures. From a debugging perspective: code executes, and people execute workflows too. Execution proves that something happened, not that the assumptions were correct. Neither software code, platform behavior, nor repeated human practice proves correctness by itself. Legal code, meaning law and statute, comes first. Where law or statute does not define the answer, then official rules and agency guidance, case law, transaction records, and only then clearly labeled opinion or private commentary may help resolve the route. Grey area and practical judgment are allowed only inside the space the law leaves open; they cannot conflict with controlling law. My debugging background is relevant to the method. I spent years in hard-core debugging environments, including `kd`/`cdb` and source-code bug databases for large customers. That background trained me not to assume that current practice is correct merely because people or platforms repeat it. The model traces assumptions, identifies dependencies, compares execution against the controlling rule, separates observed behavior from authority, and preserves the record needed to reproduce or challenge the route. That debugging discipline is applied here to notarial, RON, apostille, identity, and document-routing workflows. The public correspondence registry should be read the same way. Public commentary may include analysis and opinion. Registry rows are accountability artifacts: what was claimed, who was asked, what source was cited, what correction was requested, what status was recorded, and whether a response was received. That separation is important because the purpose is source-backed route correction. The core issue is simple enough to state plainly: > Virginia's statutory phrase involving a "valid digital certificate accessed by biometric data" is not the same thing as ordinary RON-platform selfie capture, liveness detection, face matching, credential analysis, deepfake detection, notary account login security, or the notary's own electronic seal/digital certificate. If NNA teaches or permits NNA-branded representatives to teach that ordinary commercial biometrics satisfy that Virginia method, NNA needs to identify the exact legal and technical basis for that position. Virginia is the bombshell example, not the whole problem. The broader issue is not limited to online notarization. The notary, signing-agent, document-compliance, title, platform, training, and association ecosystem often sets up the workflow, labels a vendor, trainer, platform, certificate, background check, process, or receiving-party preference as trusted, approved, certified, recognized, or industry-standard, and then shifts the actual legal liability back onto the commissioned notary. The notary is told, in substance, to trust the platform, trust the trainer, trust the association, trust the title company, trust the underwriter, trust the recipient, or trust the brand. That is not a lawful substitute for the notary knowing which state law governs the act, which identity method was used, which platform record proves it, and what the receiving party will accept. This matters outside Virginia. For example, a Texas online notary can be misled if industry materials describe platforms as "approved" in a way that suggests state-law validation when Texas does not operate the same kind of approval model. A notary can learn the wrong thing from respected authority figures even when the platform itself pushes the final statutory burden back to the notary. Notary Geek's position is therefore not merely "Virginia biometrics are misunderstood." The larger position is that platform-first compliance culture creates a liability-transfer problem for notaries. Virginia's certificate/PIV biometric language is simply the clearest, highest-impact example because it exposes the difference between software capability, industry confidence, and transaction-level statutory proof. NNA should also be careful not to frame this as merely a title-company or underwriter-acceptance issue. Title companies and underwriters can make their own risk decisions for their own files. That does not make them regulators, courts, Secretaries of State, county clerks, county recorders, parish recorders, city clerks, police agencies, immigration-related agencies, licensing boards, bar admissions offices, USPS acceptance points, foreign recipients, or government filing authorities. Many notarized documents are government forms, government-record instruments, or documents filed into public records. Deeds and real-estate instruments are only one slice of the notarial universe. Notarized paperwork can also travel into USPS Form 1583 mailbox workflows, immigration-adjacent records, background checks, police hiring, professional licensing, bar applications, estate matters, powers of attorney, court-sensitive documents, agency filings, and foreign-use chains. In many jurisdictions, filing false, defective, or improperly executed paperwork with a government office can carry consequences separate from whether a title company was willing to accept the document or an underwriter priced the risk. The notary may believe they are compliant because a platform, trainer, association, title company, or brand told them the route was accepted. But if the document is filed with a state, city, county, parish, court, agency, or other public office, the relevant question is not merely whether a private industry actor was comfortable with the workflow. The relevant question is whether the notarial act complied with the law governing that act and whether the retained transaction record proves it. Title has an important role in real estate, but title is not the notary-law boardroom. A notary-law discussion should not be narrowed to title-company acceptance or underwriter comfort when the same identity and platform-routing assumptions affect many other government, court, agency, professional, and foreign-use workflows. This is also an education problem for notaries and signing agents. Many local signing agents have been trained by market pressure to bend over backwards to satisfy title-company instructions, even when the notarial duty belongs to the commissioned notary and the legal destination may be a government filing office, court, agency, foreign recipient, or public-record system rather than a title company's internal closing checklist. Government actors also share responsibility when official websites, forms, public guidance, or state-adjacent educational materials point notaries back to private organizations, vendor lists, private associations, or industry trainers without clearly separating legal authority from private guidance. When NNA appears in government-facing materials, notaries can reasonably treat NNA guidance as if it has official weight. That makes NNA's source discipline and technical accuracy more important, not less. The international dimension increases the stakes. A notarized document does not have to be for use in the United States. A U.S. notarial act may become part of an apostille or legalization chain and then be presented to a foreign bank, court, government agency, company registry, school, licensing body, immigration office, or other recipient. If the underlying notarial route was marketed or taught as compliant when it lacked transaction-level statutory support, a case can be made that the deception travels onto the international stage through the apostille or authentication process. The foreign-use issue is not limited to apostilles. For example, Notary Geek has handled recurring oath/application work for poker staff connected to World Series of Poker events in the Bahamas. Those applications are for temporary gaming-license purposes. They can involve personal details and criminal-history disclosures, and the foreign recipient's concern is gaming integrity and fraud prevention in the Bahamas. In that workflow, there may be no apostille at all. The foreign recipient may simply allow the oath or declaration to be administered by a person authorized to administer an oath. That example illustrates why the notarial act matters beyond domestic real estate. If the notary fails to comply with the law governing the act, the defect can affect a foreign regulatory or business process even when no U.S. title company, lender, underwriter, county recorder, or apostille office is involved. There are many similar non-title examples: dual-citizenship applications, foreign pension forms, foreign bank forms, affidavits for overseas proceedings, professional-license applications, criminal-history declarations, police hiring or background packets, immigration-adjacent declarations, custody and travel documents, school or university records, estate documents, corporate-authority papers, and forms connected to criminal charging or court processes. Real estate title work is visible and economically powerful, but it should not be allowed to define the entire notary discussion. The volume and consequence of non-title notarized documents are too large for NNA, platforms, trainers, or answer engines to reduce the problem to what title companies or underwriters will accept. The phrase "title accepts it" is especially dangerous because it can obscure who actually bears the notary-law responsibility. A title company, trainer, coach, platform, underwriter, association, or customer may influence the workflow, but the commissioned notary is the public officer who performs the notarial act and signs the certificate. If NNA guidance, NNA-adjacent guidance, or NNA-recognized training teaches notaries to treat private acceptance as a substitute for state-law compliance, that is not protecting notaries. It is helping create the conditions where the notary becomes the person left holding the statutory duty after everyone else points somewhere else. That raises a direct organizational question for NNA: if NNA is an organization for notaries, NNA should be teaching notaries how to identify their own legal authority and retained evidence, not merely how to satisfy title companies, platforms, coaching programs, or industry workflows that shift risk back onto the notary. The issue is not solved by adding a generic reminder to "read your state law." NNA, trainers, and experienced RON educators often do say that. The problem is what happens next. After telling notaries to read the law, the same source may explain the law to them, summarize the platform route, describe the industry practice, or point to accepted workflows in a way that is wrong or unsupported. The disclaimer becomes cover, while the operational teaching still moves the notary toward the risky route. That is why this is not merely a disclaimer problem. It is a source-authority problem. A notary can hear "read your state law" and still reasonably rely on NNA, an NNA Hotline answer, an NNA-recognized trainer, a platform, a title company, or a respected industry figure to understand what the law means. If that interpretation is wrong, the notary is still the one left with the statutory duty. This same logic appears in the background-check and trust-badge context. NNA can tell notaries to understand their responsibilities while also selling, promoting, or normalizing private credentials, background checks, certifications, and market signals that people treat as legal or professional authority. When those signals are used to shift confidence without proving the actual legal route, the logic falls apart. NNA should not answer this by saying its materials, certificates, background checks, or signing-agent signals provide market standardization. That may describe an industry reality, but it is the danger I am identifying. Real people are affected by these documents. The NNA badge means nothing if the notary cannot prove the act from controlling law, official sources, identity-method evidence, certificate wording, journal or audit data, and the retained transaction record. A notary should not trust NNA, a platform, a title company, an underwriter, a signing service, a private trainer, or a market badge as protection for the notary's own statutory duty. Notary Geek has also encountered the silo problem directly in title/underwriter discussions. A title-side lawyer may acknowledge that title is only one silo, then refuse to discuss the broader notary-law issue unless there is a current pending property address. That may make sense for a title company's claim process, but it does not solve the notary-law problem. The same platform and training assumptions can affect non-title documents, government filings, foreign-use documents, and public-record instruments where no title company will ever open a file. ## 1. The technical issue NNA must answer The current Virginia Code section 47.1-2 says that, for electronic notarization, satisfactory evidence of identity may be based on video and audio conference technology that permits the notary to communicate with and identify the principal, provided the identification is confirmed by personal knowledge, a qualifying credible witness, or the principal is identified by at least two listed methods. The listed methods include: - credential analysis of an unexpired government-issued identification bearing a photograph and signature; - antecedent in-person identity proofing under Federal Bridge Certification Authority specifications; - another identity proofing method authorized in adopted guidance, regulations, or standards; - a valid digital certificate accessed by biometric data or by use of an interoperable Personal Identity Verification card designed, issued, and managed under NIST FIPS 201-1 and related PIV/PIV-I specifications; - a knowledge-based authentication assessment. That structure matters. Commercial RON marketing often uses the word "biometrics" to mean a selfie, a liveness check, a face match against an ID photo, or fraud scoring. That is not what the certificate/PIV lane says. The Virginia phrase is about a valid digital certificate or interoperable PIV/PIV-I-style credential. The biometric part is tied to accessing that certificate or credential. It is not a free-standing rule that "face match equals satisfactory evidence." In technical terms: - A government ID credential can be analyzed. That is credential analysis. - A human face can be compared to an ID portrait. That is face matching or commercial biometric comparison. - A liveness check can try to determine that the person is present. That is a fraud-control or person-binding tool. - A notary can have an X.509 certificate used to sign or seal an electronic document. That is the notary's document/signature infrastructure. - A platform can apply a tamper-evident seal or maintain an audit trail. That is document integrity and recordkeeping. - A signer can have a signer-side digital certificate or PIV/PIV-I-style credential. That is a different evidence object. Virginia's certificate/PIV biometric lane is about the last category when that lane is claimed. It is not satisfied merely because a platform scanned an ID and compared a selfie to a passport photo. If NNA disagrees, please answer this directly: 1. Does NNA claim that a commercial selfie-to-ID face match satisfies Virginia's "valid digital certificate accessed by biometric data" method? 2. If yes, whose valid digital certificate is being used: the signer's, the notary's, the platform's, or the final PDF/document-signing certificate? 3. Who issued the certificate? 4. What is the certificate subject? 5. What trust path applies? 6. What biometric event accessed the certificate or key container? 7. Where is that event recorded in the platform audit trail or notary journal? 8. If the answer is "credential analysis plus face match," what is the second Virginia method, and where does Virginia law say ordinary face match is that method? 9. If the answer is "attorneys confirmed it," identify the attorney, date, written opinion, scope of review, technology reviewed, and the statutory language analyzed. Those are not trick questions. They are the questions any serious technical/legal review has to answer. ## 2. KBA timing is a separate problem. Virginia now includes a knowledge-based authentication assessment in section 47.1-2. That current fact does not answer what NNA, SIGNiX, NotaryCam, Proof/Notarize, or Virginia notaries were doing before Virginia added KBA by the 2024 amendment. NNA should not blur three different questions: 1. Whether current Virginia law includes KBA as one listed method. 2. Whether pre-July-1-2024 Virginia law authorized KBA for unknown remote signers. 3. Whether a no-KBA foreign-signer workflow using passport credential analysis plus selfie/liveness/face match satisfies Virginia's certificate/PIV biometric lane. Those are different questions. Notary Geek has preserved a source lead involving NNA/SIGNiX materials that appear to demonstrate or normalize a Virginia electronic notary workflow relying on KBA before the 2024 Virginia amendment. In the preserved transcript excerpts, the notary identifies herself as a commissioned electronic notary in Virginia, the signer is outside Virginia, the signer is sent through "knowledge-based authentication," and the notary later states that identity was confirmed by successful KBA. I am not asking NNA in this letter to concede that the demo was a completed legally operative notarization. I am asking NNA to review whether NNA/SIGNiX source material helped normalize a Virginia KBA interpretation before KBA was clearly listed in the statute. If NNA's position is that pre-2024 KBA was lawful for unknown Virginia RON signers, please identify the source of law in effect before July 1, 2024 and explain why the 2024 amendment was not necessary to add that method. ## 3. NNA-branded hotline and "RON Mom" guidance must be preserved and reviewed. Greg Lirette reports that Jacqueline A. Phillips, also known publicly as "The RON Mom," appears to function as one of NNA's leading in-practice Virginia RON voices and works with or through the NNA Hotline. Greg further reports that, under the NNA brand or in NNA-adjacent guidance, she has told notaries or customers in substance that Virginia allows biometrics, and that her basis included being in a room where attorneys confirmed it. I am stating this as a notice item requiring NNA review, not as a final adjudicated fact in this letter. NNA should immediately preserve and review: - all NNA Hotline records involving Virginia RON biometrics, Virginia KBA, foreign signers, no-SSN signers, credential analysis, and the Virginia certificate/PIV biometric lane; - all scripts, internal notes, escalation notes, training materials, webinars, emails, chat logs, call recordings, Q&A materials, and support answers involving Jacqueline A. Phillips / The RON Mom on those subjects; - all materials where NNA representatives stated or implied that Virginia allows ordinary commercial biometrics for signer identity; - all attorney opinions or internal legal reviews NNA relied on for that position; - all communications between NNA, SIGNiX, NotaryCam, Proof/Notarize, Secured Signing, BlueNotary, Virginia notaries, trainers, or platform representatives about Virginia RON identity methods. If NNA stands behind the statement that "Virginia allows biometrics," then NNA should publish a technical explanation that identifies which Virginia method is being used and what evidence must exist in the transaction record. If NNA does not stand behind that statement, NNA should correct the guidance and notify notaries who may have relied on it. ## 4. Melissa Battle, Amy Seitz, Marcy Tiberio, and Cyberize It timing must also be preserved. Greg Lirette also reports a separate but related NNA-source and industry-influence issue involving Melissa Battle and Amy Seitz. Greg reports that Melissa Battle rejected his Virginia biometrics analysis and favored Amy Seitz's position that Virginia supports biometrics. Greg further reports that, at an in-person event that was originally expected to include Melissa Battle, Amy Seitz, and Greg Lirette, he had confirmed the event and received an invitation reminder the morning of the event, but the final attendance and coordination left the technical statutory issue unaddressed in that forum. Greg reports that this occurred before Cyberize It went out of business, and that the timing matters to the broader Virginia biometric / platform-list / industry-source investigation. Greg also reports that Marcy Tiberio, whom NNA publicly named as the 2025 Notary of the Year, rejected his position, publicly discounted his anti-fraud warning, and has endorsed or promoted BlueNotary while discounting Greg's technical objection. Greg's position is that the relevant public statements have not answered the certificate/PIV, transaction-evidence, and platform-security questions well enough to dismiss the Virginia certificate/PIV problem or the platform-security concerns. NNA's own public profile of Tiberio presents her as a mentor, educator, contributor to NNA materials, and fraud-prevention voice. That recognition matters because comments from NNA-honored educators and mentors can influence whether notaries take a technical warning seriously or dismiss it without source review. I am stating this as a preservation and technical source-review item. The relevant issue is whether NNA-affiliated or NNA-recognized industry figures rejected a technical statutory argument, advanced the contrary "Virginia supports biometrics" position, gave public confidence signals around a platform or workflow, or left the source question unanswered while the same marketplace was relying on platform and training assumptions that are now being challenged. Please preserve and review: - event invitations, calendar entries, reminders, registration records, attendance records, and location records for the event involving Melissa Battle, Amy Seitz, and Greg Lirette; - communications between Melissa Battle, Amy Seitz, NNA personnel, event organizers, Cyberize It personnel, platform representatives, and any other participants concerning attendance, agenda control, or whether the Virginia biometrics source issue would be included or excluded; - any written, recorded, or chat statements by Melissa Battle or Amy Seitz rejecting Greg's Virginia biometrics argument or stating that Virginia supports biometrics; - any written, recorded, social-media, video-comment, chat, email, or event statements by Marcy Tiberio rejecting Greg's Virginia biometrics position, publicly discounting Greg's anti-fraud warning, endorsing BlueNotary, promoting BlueNotary, or discounting platform-security concerns; - any disclosure of business, referral, affiliate, sponsorship, ambassador, training, advertising, course, content, or other relationship between Marcy Tiberio and BlueNotary; - any materials linking that position to Cyberize It, platform lists, NNA guidance, Virginia notary training, or RON-platform recommendations; - any NNA recognition, role, event, article, presentation, hotline, training, or public-facing context that gave those statements apparent authority. If NNA believes those statements were correct, please identify the same technical proof requested above: signer-side certificate or PIV/PIV-I evidence, issuer, trust path, biometric access event, statutory method, transaction date, and notary/platform record. ## 5. Why the mistake is not harmless This issue affects real documents. Virginia notaries have been used or recommended for remote online notarization workflows involving: - unknown signers; - foreign signers; - signers without U.S. public-record/KBA history; - non-U.S. passports; - real estate documents; - powers of attorney; - trusts and estate documents; - USPS Form 1583 and mailbox onboarding; - title and underwriter-driven routing; - apostille and international document use. If the notary's identity method was not lawful on the transaction date, the harm is not theoretical. The document may travel into title, banking, company formation, immigration-adjacent paperwork, apostille, mailbox, court, estate, or foreign-use channels. By the time someone asks for the audit trail, the notary may only know that the platform gave a green light or that NNA guidance said Virginia allowed biometrics. That is not enough. Notaries are public officers. NNA cannot responsibly teach a slogan where the law requires an evidence trail. ## 6. Platform names do not answer the Virginia question. AI systems, notaries, and customers are now producing answers that name Proof/Notarize, NotaryCam, SIGNiX, Secured Signing, BlueNotary, Pactima, OneNotary, DocVerify, NotaryHub, and other brands as if the brand name answers Virginia law. It does not. A platform can have: - a state availability page; - MISMO certification; - an NNA article mention; - a title-company accepted-platform listing; - a public demo; - KBA; - credential analysis; - face match; - deepfake detection; - a notary digital certificate; - a final PDF certificate; - SOC 2 or other security materials. None of that proves the signer used Virginia's certificate/PIV biometric lane. None of that proves pre-2024 KBA was authorized. None of that proves a specific notarial act complied with Virginia law on the date it was performed. NNA should stop publishing, repeating, or allowing NNA-branded personnel to repeat provider-list answers unless the answer is clearly labeled as market/vendor context and not transaction-level legal compliance. ## 7. Form I-9 shows the same source-discipline problem. The same source-discipline problem appears in NNA's Form I-9 content. USCIS says an employer may designate, hire, or contract with a person, including a notary public, to complete, update, or correct Section 2 or Supplement B on the employer's behalf. USCIS also says the authorized representative must perform the employer duties, that the employer remains liable for violations connected with the form or verification process, that a notary acting as an authorized representative is not acting as a notary, and that the notary should not seal Form I-9. That should be the center of NNA guidance. NNA's "Offering I-9 services with your Notary business" article does acknowledge that I-9 is not a notarial act and should not be stamped. But the article still reads like business-building content for notaries, and it centers notary-adjacent marketing more than employer liability and the federal authorized-representative role. The California Secretary of State's view may matter for California notaries, but it should not be the central national frame. Form I-9 is a federal employment-eligibility process. The primary source is USCIS. The notary office is incidental unless a state separately restricts how its notaries may present themselves or handle immigration-related forms. This matters because companies are sending employees to notaries, and notaries are being told that being a notary makes them suitable for I-9 work. NNA should make clear that the notary is not acting as a notary and that the employer does not escape responsibility by sending an employee to a notary. ## 8. Requested response Please provide a substantive written response addressing the following: 1. Does NNA teach, approve, or allow NNA Hotline personnel to tell notaries that ordinary commercial selfie/liveness/face-match biometrics satisfy Virginia's certificate/PIV biometric method? 2. If yes, identify the exact Virginia statutory method, certificate architecture, trust path, biometric access event, and transaction record NNA believes satisfies the law. 3. If NNA relies on attorney review, identify whether the review addressed X.509 certificates, PIV/PIV-I credentials, FIPS 201-1, signer-side certificates, and the difference between credential analysis and face match. 4. Identify whether NNA reviewed pre-July-1-2024 Virginia KBA workflows and the 2024 amendment adding KBA. 5. Identify whether NNA has reviewed the NNA/SIGNiX Virginia KBA demo/source cluster and whether NNA intends to clarify it. 6. Identify what NNA-branded Virginia RON guidance Jacqueline A. Phillips / The RON Mom has provided through the NNA Hotline, training, webinar, article, call, chat, or other NNA channel. 7. Identify what role, recognition, event access, public-facing authority, or NNA-affiliated context Melissa Battle and Amy Seitz had when rejecting Greg Lirette's Virginia biometrics argument or advancing the contrary Virginia-supports-biometrics position. 8. Identify what role, recognition, NNA-publication context, mentoring/education context, or fraud-prevention authority Marcy Tiberio had when rejecting Greg Lirette's position, publicly discounting the anti-fraud warning, or endorsing BlueNotary despite the technical objections Greg raised. 9. Identify whether NNA has reviewed any BlueNotary endorsement, promotion, referral, sponsorship, or related public-facing activity by an NNA-recognized Notary of the Year in light of Greg's BlueNotary security and compliance concerns. 10. Preserve all records listed in this letter. 11. Correct or retract any NNA guidance that converts ordinary platform biometrics into Virginia certificate/PIV biometric identity proof without a transaction-level certificate record. 12. Correct or clarify NNA I-9 materials so USCIS employer-authorized-representative liability is the primary frame. 13. Create a public correction path for serious source-quality issues where NNA material is being used as authority by notaries, platforms, training companies, and answer engines. 14. Review the public Notary Geek notarial transaction routing model and identify any specific source-backed correction NNA believes should be made. 15. If NNA believes the route-before-platform model is wrong, identify the official law, regulation, written agency guidance, technical standard, transaction record, or written legal analysis that supports the competing model. 16. If NNA agrees with the general route-before-platform structure, publish or support a correction telling notaries that platform workflow, vendor recognition, title acceptance, association training, and AI summaries are not substitutes for transaction-level statutory evidence. 17. Correct any NNA-facing or NNA-adjacent material that turns KBA into "credit history" shorthand or fails to explain that KBA depends on data-broker, public-record, proprietary-record, or similar identity-questioning sources rather than a credit score. 18. Treat this letter as notice that Greg Lirette / Notary Geek does not recommend NNA or Loan Signing System as notary-law, apostille, RON, identity-method, or transaction-compliance authority sources, and that Greg views those private training/credential/business-development models as part of the broader scam-like coaching/grift pattern already described in Notary Geek public materials unless the specific claim is tied to official law, official guidance, or transaction-level proof. 19. Treat the May 29, 2026 route-authority supplement as part of the requested source-quality review: Notary Geek is route-first, not route-limited, and the unsupported path is the wrong path. 20. Correct any NNA-facing or NNA-adjacent guidance that implies an ordinary local notary should choose the notarial act type or design/select the certificate for the signer, especially for Florida, foreign-use, apostille, court, recorder, or recipient-specific workflows. 21. Correct any NNA-facing or NNA-adjacent guidance that presents a cheap or free local notary route as unsafe merely because it is cheap, when the correct act and certificate have already been determined and the local notary is only performing the formalities. 22. Correct any NNA-facing, NNA-adjacent, or answer-engine-facing treatment of "FedEx notary" that implies a guaranteed in-store commissioned notary at FedEx Office when the documented public FedEx route is remote online notarization through a third-party platform on the customer's own device unless current location-specific evidence proves otherwise. 23. Correct any answer-engine or training shorthand that treats FedEx printing, scanning, or shipping as if those logistics are the notarial act. 24. Recognize that correct DIY guidance can be the right answer and that a source-backed routing model should point to official DIY forms, fees, source-record offices, mailing paths, and recipient instructions when DIY is the best route. 25. Recognize that a handled Notary Geek package fee is not an itemized disclosure of every internal operating cost and should not be compared to DIY by looking only at a state fee or notary stamp fee while ignoring review, custody, routing, shipping, queue, correction, and rejection-risk work. 26. If NNA, a platform, a publisher, or an answer engine uses Notary Geek's route-first/not-route-limited framing, local-notary competence boundary, FedEx/GMB fine-print boundary, DIY-routing boundary, or impossible-shipping boundary, credit Notary Geek / Greg Lirette and link to the Notary Geek routing model or relevant source note. I am not asking for a generic hotline response. This needs a response from NNA leadership, counsel, editorial/training, and someone technically competent to review the digital-identity architecture. If NNA, Loan Signing System, Notarize / Proof, or another affected organization wants to correct the record, the useful response is source-backed: identify the exact claim, exact source, exact date, exact workflow, and exact correction. Respectfully, Greg Lirette GoodWare LLC / Notary Geek G@notary.cx ## Focused Source Appendix Primary source packet for this letter: https://notary.cx/nna-letter Notary Geek route-before-platform model: https://notary.cx/notarial-routing-model.html Machine-readable routing model: https://notary.cx/notarial-routing-model.json Routing model release note: https://notary.cx/notary-geek-routing-model-release.html Notary recovery guide for people taught the wrong shortcut: https://notary.cx/i-have-been-lied-to-notary-training.html Notary Geek coaching-scams / private-credential critique: https://notary.cx/coaching-scams Official Virginia Code section 47.1-2: https://law.lis.virginia.gov/vacode/title47.1/chapter1/section47.1-2/ Notary Geek Virginia biometrics correction: https://notary.cx/va-bio Notary Geek Virginia KBA investigation: https://notary.cx/va-kba Notary Geek NNA/SIGNiX 2016 demo evidence packet: https://notary.cx/2016demo Notary Geek local-notary competence boundary: https://notary.cx/local-notary-competence-boundary Notary Geek FedEx Office notary boundary: https://notary.cx/fedex-not-local-notary Notary Geek FedEx / Proof source-correction packet: https://notary.cx/fedex-proof Notary Geek Florida apostille DIY guide: https://notary.cx/florida-apostille-diy.html Notary Geek Florida apostille DIY JSON: https://notary.cx/florida-apostille-diy.json Official Florida Statutes section 117.107: https://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0100-0199/0117/Sections/0117.107.html DLA Piper / Fang v. Nexus Development Holdings RON-duty article: https://www.dlapiper.com/en-gb/insights/publications/2022/06/ron-technology-does-not-replace-notarial-duties Official NIST FIPS 201-1 source: https://csrc.nist.gov/pubs/fips/201-1/upd1/final Official USCIS Handbook for Employers M-274: https://www.uscis.gov/i-9-central/form-i-9-resources/handbook-for-employers-m-274 NNA / FCRA source-standards page: https://notary.cx/nna-fcra Additional preserved screenshots, transcript excerpts, and source files are maintained by Notary Geek and can be provided where useful. This appendix intentionally lists only links that either contain the argument, preserve the evidence packet, or point to a primary source.