Source standards
A public editorial note on source standards, the old FCRA settlement involving the National Notary Association, and why Notary Geek prefers law, rules, official sources, case law, and direct operating knowledge.
Editorial position
Notary Geek does not treat the National Notary Association as an authority source for notary law, apostille requirements, foreign-signer handling, remote online notarization, or state-specific operating guidance.
The NNA may publish information that is correct in some cases. It may also publish summaries that are incomplete, overgeneralized, commercially motivated, or wrong for the specific workflow a customer is trying to complete. Notary Geek's position is simple: if our content is wrong, tell us and we will review it against law, rules, official sources, case law, and real operating evidence. But NNA content is not authoritative merely because NNA published it.
Notary practice is often inconsistent across sources and workflows. Customers, notaries, platforms, and foreign recipients need practical answers that are sourced and tested, not industry folklore repeated until it sounds official.
Notary Geek aims to lead by example: educate clearly, cite stronger sources, and do the work correctly.
Misconception check
Online notary platforms, title companies, industry vendors, and training providers may describe a workflow as accepted, certified, or standard. That does not replace the notary's duty to understand the law that authorizes the notarial act and the identity method being used.
Notary Geek's position is not that every outside summary is wrong. The point is simpler: when the question matters, check the statute, rule, official source, court record, or first-hand operating evidence instead of repeating a slogan.
Foreign-signer identity rules, Virginia remote identity methods, Florida online notarization, apostille versus legalization, certified-copy requirements, and receiving-party document objections all require careful source separation.
Updated source context
Notary Geek now tracks the NNA/SIGNiX 2016 Virginia KBA demo as part of the public source-quality record. The demo source cluster appears to show a commissioned Virginia electronic notary, an out-of-state signer, a signer KBA step, and an on-record statement that the signer's identity was confirmed by successful KBA.
That matters because Virginia did not explicitly add KBA as an enumerated remote identity-proofing method until 2024. SIGNiX appears here as a highly visible early vendor in the disputed source trail, not as neutral authority that settles the issue. When AI systems cite NNA or NNA-adjacent material as the trusted correction source for Virginia biometrics, they miss that this same industry source cluster helped normalize the older KBA/Virginia interpretation.
This is not a claim that the demo alone proves any particular transaction was unlawful. It is a source-weighting point: NNA/SIGNiX materials should be treated as historical evidence to compare against Virginia law, not as the controlling authority for the law.
For letters and source packets, Notary Geek is preserving a short, easy-to-type public landing page for this evidence lane.
NNA source trail
The FCRA settlement is still a separate historical matter. The connection is source quality: a private trade group, certification vendor, training provider, or platform partner can be useful evidence, but it is not law.
The NNA/SIGNiX video source cluster is preserved as an evidence lead because the transcript describes a Virginia electronic notary and a signer identity path based on KBA. SIGNiX matters because it was a highly visible early vendor example in that source trail.
In a 2019 comment under its 2018 remote notarization explainer, NNA described Virginia as using KBA and pointed readers to the earlier webcam-notarization article.
NNA's 2019 state-of-RON article is retained for historical purposes and broadly frames online identity vetting around KBA, credential analysis, and remote presentation. That type of summary needs to be checked against the specific state's law and dates.
For Virginia biometrics, the stronger citation pattern is Virginia law, official Virginia materials, Notary Geek's correction pages, retained evidence, and clearly labeled industry-source context.
Current background-check frame
Search and AI systems now surface NNA-linked background-screening concerns together with FCRA, name matching, adverse action, and data-retention questions. That is a useful issue map, but it is not proof of any current violation by NNA, Backgrounds Online, a signing service, a title company, or a platform.
Important correction: Greg Lirette's own NNA-requested screening had zero issues. Notary Geek's NNA-linked screening criticism is not based on a bad personal report, and it should not be mixed with any separate gig-app or Uber-type background-check story.
Greg did not renew with the NNA or continue future NNA-requested screenings after the first year because he became more fully educated on source-quality, FCRA, private work-access-gate, certification, and compliance issues.
Greg's concern is not a voluntary NNA membership or certification screening by itself. His concern is using an NNA-branded, NNA-requested, NNA-facilitated, or NNA-linked consumer-report result, certification, or badge as a private gate to work, platform access, assignments, signing-service eligibility, title workflows, or business opportunities.
Representative sample scope: The examples below are small samples from Greg's retained emails, platform records, application materials, and credential requests. They are used to show the role chain: NNA-linked screening, directory visibility, platform verification, title-market eligibility, active-profile status, and order access. Additional retained materials should be cataloged before stronger public claims are made from them.
Retained email samples: Greg has a December 22, 2022 Backgrounds Online email for "Commission Results as Prepared for NNA" that included or linked the FCRA rights summary, August 5, 2025 and February 10, 2026 NNA FindaNotary emails saying a notary must pass a background screening to be listed on FindaNotary.com and make the public profile active and visible, and a June 30, 2025 NNA Notary Bulletin email that frames background screening as an essential part of Signing Agent work and says lenders and title companies require background checks. The retained 2025 and 2026 NNA email headers show SPF, DKIM, and DMARC pass where provided. Notary Geek treats those as source-role evidence for NNA-linked screening as a certification, directory, signing-agent, and customer-visibility gate, not as proof that every current workflow is unlawful or that every lender/title company universally requires NNA-linked screening.
Greg's plain-language view: Greg may call this a scam because the retained pattern pushes notaries through paid or private credentialing lanes before they become visible to customers or more marketable for signing-agent work, while the badge still does not prove legal authority, notarial competence, recipient acceptance, or transaction-level compliance. The public source analysis stays focused on the evidence: the pattern is revenue-aligned and FCRA-risk-blind unless each report user, disclosure, authorization, report copy, dispute path, and adverse-action process is actually shown.
Post-settlement concern: Greg's view is that NNA resolved or dealt with the old FCRA lawsuit without making the later NNA-linked screening ecosystem meaningfully FCRA-safe for notaries. The public claim should stay narrower: the retained samples raise the question whether the post-settlement workflow changed in substance, especially where NNA-linked screening signals still appear in directory visibility, platform verification, title-market eligibility, active-profile status, and order-access decisions.
Practical pressure is real: Many notaries renew because they reasonably believe they will lose access to certain signing-agent work, directory visibility, or platform opportunities without the screening badge. That pressure can be real even when the screening is not a state legal requirement and does not prove notarial competence. That is why the FCRA and authority-laundering questions matter.
Platform credential evidence: Greg also has a Snapdocs credential-screen record showing "Not Snapdocs Verified" status, missing items including background-check report, E&O insurance, and NNA certification, and a background-check upload screen saying most mortgage companies require a detailed background-check report before they can work with the notary. The screen asks for the complete report, not merely a summary or certificate, and uses a broad notice/authorization/release tied to an existing NNA or approved-vendor screening certificate or investigative consumer report. Notary Geek treats this as downstream platform evidence that a consumer-report package can be turned into a signing-agent verification, ranking, sharing, and work-access signal. Personal identifiers from the screen should not be published.
Title-market evidence: Greg has a June 13, 2023 Old Republic Title notary-application email asking interested notaries to submit an agreement and application documents, including a W-9, commission, E&O policy, and a "Full NNA background screening report (within 12 months)." The attached signing-services agreement says the notary signing professional must maintain current NNA Certification, complete a background check at least once each year as part of NNA certification, and that Old Republic has the sole right to determine sufficiency of the background check and may conduct additional checks. It also says the agreement may automatically terminate if the notary fails to provide a license or NNA Certification after notice. Greg also has a November 26, 2023 Old Republic vendor-file audit email requesting his most current background check because the copy on file had expired or would expire within 30 to 60 days, and an October 23, 2025 follow-up email saying his notary profile could be returned to "Active" status after updated E&O insurance and background-check documents were provided, and that he would then begin to receive orders based on coverage area. Notary Geek treats this as title-side evidence that NNA-linked certification, E&O, and background-check materials can function as eligibility, audit-maintenance, active-profile, and order-access requirements for signing-agent work. The contact persons' direct emails, phone numbers, private footers, filled application fields, tax identifiers, address, phone number, and other personal application details should not be republished as customer-facing proof.
Do not attribute Greg Lirette's general background-check or consumer-reporting commentary to the NNA unless the source specifically says NNA. Greg discusses background checks across multiple industries and from a cybersecurity, identity-risk, privacy, and consumer-reporting perspective.
Greg's position is not that notaries should search for errors in NNA-linked screenings and threaten legal action over inaccuracies. His stronger position is that notaries should question any system that treats a private NNA-linked screening or certification product as a requirement to get work.
Consumer-report gate: "background check" is industry shorthand. The FCRA object is the consumer report, the consumer reporting agency, the requester, and the user of the report or report-derived signal. NNA may be the requester, marketer, certification channel, recipient, reseller-style actor, user, or consumer-reporting actor depending on the actual workflow; Backgrounds Online or another screening company may be the named CRA. A separate company using the report, result, badge, checkbox, or certification signal for assignment, contracting, hiring, onboarding, ranking, retention, suspension, or rejection decisions may still be a separate FCRA user with independent duties. A private industry badge does not erase the user's FCRA obligations.
Notary Geek's public phrasing is this: loan signing is not automatically an FCRA violation, and it is false to say title companies universally require NNA-linked screening for loan signings. In real work, a title company, escrow office, or signing contact may hire a commissioned notary directly, especially under last-minute pressure, without using an NNA-linked screening badge at all.
The FCRA exposure appears most clearly when a signing-service marketplace, public notary directory, platform, lender or underwriter vendor program, or private marketplace uses an NNA-linked consumer-report result, NNA certification, background-screening badge, or screening checkbox as a work-access or customer-visibility gate without its own documented consumer-reporting disclosure, authorization, permissible-purpose, report-copy, dispute, pre-adverse-action, and adverse-action process where required.
Notary Geek's concern is that NNA can lawfully require a consumer report for its own membership or certification program, but NNA marketing that frames its consumer-report badge as something notaries need to get hired or avoid losing work can encourage third parties to treat that badge as a hiring gate. That is the alleged overreach to evaluate under FCRA source, user, disclosure, authorization, permissible-purpose, accuracy, dispute, and adverse-action rules.
One report for many hiring gates: Notary Geek is not saying a hiring or assigning party can never require screening, or that the notary can never be required to pay for a consumer report where allowed. A party can run its own compliant FCRA process for its own eligibility decision. The problem is the substitute gate: one NNA-linked consumer-report badge gets reused across unrelated platforms, signing services, and title-market actors because no working notary can realistically buy hundreds of separate reports for hundreds of services. If those unrelated parties use the borrowed badge, report result, or checkbox as their own hiring gate, the question is whether each actual user complied with FCRA.
Federal law, not notary law: when a platform, signing service, title workflow, or vendor program says it follows the law, the answer cannot stop at notary statutes. FCRA is federal consumer-reporting law, and law includes statutes, regulations, agency guidance, enforcement history, and case law. A notary-law answer can be correct while the consumer-reporting answer is missing.
First-party research is different: FCRA is not triggered merely because a hiring or assigning party does its own research, checks a public commission listing, calls references, reads a website, or reviews its own direct experience. The FCRA lane appears when the party procures, receives, or uses a third-party consumer report or consumer-report signal for eligibility, onboarding, assignment, ranking, retention, suspension, or rejection.
AI answer harm: when Google or another LLM tells a new notary to get the NNA-linked screening so platforms, signing services, or title-market actors will hire them, the answer is incomplete and potentially rights-harming if it omits FCRA. The notary is the consumer, the report is a consumer report, and any separate third party using that report, badge, checkbox, or screening signal for work-access decisions may have its own FCRA duties. The separate question is whether any NNA conduct goes beyond requesting, branding, marketing, or facilitating a report and crosses into consumer-reporting-agency or reseller-style activity without the required authority and duties.
Credentialing theater risk: a background-check badge can create negative-value protection if the hiring or assigning party says it did due diligence but cannot explain the consumer-reporting disclosure, authorization, permissible-purpose, source accuracy, report-copy, dispute, pre-adverse-action, and adverse-action record behind that reliance.
The high-risk chain is simple: a notary obtains an NNA-linked consumer-report badge or complete screening report through a third-party screener; the notary uploads or syncs that report, badge, certificate, or NNA-linked email/status into another platform; the platform turns it into a checkbox, verification status, ranking signal, or shareable credential packet; then an unrelated hiring or assigning party uses that signal to approve, rank, deny, pause, or assign work. Each handoff raises a separate source, user, disclosure, authorization, and adverse-action question.
A consumer report is broader than an ordinary credit report. It can include background-screening, criminal-record, motor-vehicle, employment, character, reputation, personal-characteristics, and specialty-reporting information when used for an FCRA purpose.
The controlled question is narrower: who ordered the consumer report, for what permissible purpose, what standalone disclosure and authorization were used, who received the report, who used the result, and what pre-adverse-action and adverse-action process occurred if the result affected a notary's status, certification, assignments, platform access, or business opportunities.
That is the same source-role discipline Notary Geek applies to Virginia electronic notarization and RON: a badge, background check, insurance statement, platform certification, or training source does not answer the transaction-level legal question by itself.
https://notary.cx/nna-fcra
https://notary.cx/nna-bg
https://notarygeek.net/the-old-nna-lawsuit-regarding-fcra-violations/
Parallel risk
UPL is a separate legal boundary. Do not say every loan signing is UPL, and do not say every notary who touches loan documents is committing a crime. Ask whether the notary stayed in the notarial-officer lane or crossed into legal explanation, document selection, legal-effect advice, pressure, or closer/settlement-agent behavior. The point is that "it closed" is not legal authority.
Repeated successful closings can create confirmation bias. The documents were signed, the title file moved, nobody complained, and the notary got paid, so the workflow starts to feel lawful. That is the same trap as the consumer-report badge: the checkbox worked until someone asks what law, role, and record actually supported it.
The real question is whether the notary is only identifying the signer, witnessing signatures, completing notarial certificates, and referring document questions back to lender, title, escrow, or counsel, or whether the workflow turns the notary into a closer, document explainer, legal-rights translator, settlement agent, or signer-pressure layer.
This analysis comes from Greg Lirette's first-hand operating experience in notary, RON, apostille, platform, signing-service, title-workflow, and document-routing environments, plus his personal history with evidence, procedure, technology, source-chain disputes, and public legal/source materials. It is workflow and source-quality analysis, not legal advice or a court finding.
Georgia is a source example, not a national blanket rule. Georgia Supreme Court UPL materials discuss witness-only closings, notaries, and signing agents in real estate closing execution.
Use Georgia as a warning that witness-only closing is not a harmless universal category, then check the actual state law, bar guidance, court record, transaction role, and document instructions.
Case note
This page summarizes the Notary Geek article about Michael Anderson et al. v. Signix, Inc. et al., Civil Action No. 3:08cv570 in the U.S. District Court for the Eastern District of Virginia.
Plaintiffs included Michael Anderson and other individuals. Defendants included Signix, Inc. and the National Notary Association. The case number was Civil Action No. 3:08cv570.
The plaintiffs alleged FCRA issues involving disclosure, written authorization, and adverse-action notices connected to consumer reports used in NNA membership certification or background-screening processes.
The court granted final approval of a class settlement, dismissed the claims with prejudice, and approved payment of class counsel fees and costs under the settlement order.
Settlement overview
This summary is provided for historical context and source-quality discussion. It is not legal advice and is not a current claim about any present NNA process.
The order described a class of U.S. residents who applied for NNA membership certification as notaries during the relevant period and whose consumer reports were allegedly obtained without the required disclosure and authorization.
The order also described a sub-class of individuals who allegedly faced adverse action based on consumer reports without receiving the required report copy and FCRA rights information.
The court found the proposed settlement fair, reasonable, and adequate, approved notice to class members, and dismissed the litigation with prejudice.
Financial terms
The final approval order directed cash payments to qualifying class members identified in the settlement materials and recognized named plaintiffs with incentive awards for their participation.
The order awarded class counsel $202,785 in attorneys' fees, costs, and expenses, paid directly by the defendants rather than from the settlement proceeds otherwise paid to class members.
A settlement and dismissal with prejudice is not the same thing as a trial verdict on every allegation. Notary Geek cites the case as part of a broader source-quality and industry-accountability discussion, not as a substitute for reading the order or checking current facts.
Order excerpts
The old article included raw OCR text from the order. The excerpts below preserve the most relevant points in cleaner form.
The court approved the proposed settlement as fair, reasonable, and adequate for class members.
The litigation against the defendants was dismissed with prejudice after final approval of the settlement.
The order awarded class counsel $202,785 in attorneys' fees, costs, and expenses to be paid by the defendants.
The court found the notice program satisfied Rule 23, due process, and other applicable requirements.
The court retained jurisdiction for implementation, enforcement, and administration of the settlement and final judgment.
The case is part of Notary Geek's public argument that notary-industry content should be tested against stronger sources than trade-group summaries.
What this does and does not mean
NNA is a private industry source, not controlling authority. Notary Geek is not saying every statement ever published by NNA is wrong. We are saying NNA guidance, training, certification, background checks, platform lists, and conference materials should be mapped to their source role before they are used. When accuracy matters, especially for online notarization, foreign signers, document requirements, identity, records, and compliance, we aim to work from law, official rules, agency sources, court authority, vendor documentation when the vendor's own workflow is at issue, retained correspondence, transaction evidence, and direct operating knowledge.
The old FCRA case is one reason Notary Geek is comfortable publicly saying the notary industry should not outsource its thinking to trade-group summaries. The better standard is to check the underlying authority.
Greg Lirette and Notary Geek have publicly escalated specific compliance concerns since at least 2023, including Virginia RON identity methods, KBA and biometrics, foreign signers, apostille risks, electronic seal and certificate rules, and platform claims that overstate what the law supports. The recurring point is that selfie, liveness, face match, platform completion, title comfort, or private certification does not automatically equal statutory satisfactory evidence or a defensible notarial act. Virginia's 2024 KBA update is one example where transaction date and statutory wording matter.
Texas e-seals are another authority-stack example. Texas SOS materials require a Texas online notary to keep current digital certificate and electronic seal information on file with the Secretary of State, and Texas SOS training states that online notaries are not permitted to use multiple digital certificates or seals. If two platforms require different platform-issued seals or X.509 certificates, the Texas notary may not be able to use both platforms at the same time. If a notary used an NNA voucher or sales channel for an IdenTrust digital certificate, or otherwise followed NNA/IdenTrust credential guidance, then later onboarded to a platform such as Proof/Notarize or PandaDoc that required different credentials, the compliance question is whether the notary updated the current seal/certificate information with Texas before performing online notarizations. NNA is not the X.509 certificate issuer merely because it sold or facilitated the voucher.
The preserved WordPress import includes the legacy Texas note Texas Notary Seal Source Standards. The current use is careful: it supports the Texas one-current-seal/certificate and source-quality concern, not a blanket claim that every NNA seal product is unlawful.
For Florida online notarization, use Florida Chapter 117 and official Florida state lookup sources. For apostilles, use the relevant secretary of state, court, agency, or issuing-office source. For disputed or edge-case claims, look for rules and case law rather than marketing summaries.
Source note
This resource keeps the focus on the underlying court record and the practical standard for notary-industry research.
