Unmasking the NNA | Investigation No. 3
Inside the Signing Professionals Workgroup: Who Sets the Standards?
An examination of the Signing Professionals Workgroup's original membership fees, the NNA's documented governance role, and the standards affecting independent signing agents.
By Tye Brown | Founder, National Notary Coalition
· 6 min read
Who established the standards that signing agents are expected to follow?
Independent Notary Signing Agents encounter requirements involving background screening, training, examinations, insurance, and professional conduct. Some come from contracting companies. Others reflect standards developed by the Signing Professionals Workgroup (SPW).
In our investigation into the CFPB and the development of SPW industry standards, we examined the Consumer Financial Protection Bureau (CFPB) and the industry's response to service-provider oversight. That followed our investigation into the missing cash form. Here, we examine the SPW's own documents: who organized the workgroup, how members participated, and what changed.
1. The NNA's founding role is written into the 2013 rules
The SPW's December 4, 2013 Rules and Procedures, Version 1.1, states in Section 1 that the National Notary Association (NNA) created the workgroup in 2013 following meetings among lenders, title insurers, and mortgage closing vendor-management companies. Section 4.1.1 identifies the NNA as the SPW's founding member. Section 4.1.2 assigns the NNA approval of initial applicants for regular membership.
The rules describe a structure in which regular members came from mortgage lenders and title insurance organizations. Associate membership included other industry participants, such as signing services, educators, associations, and background-screening providers. The 2013 rules gave regular voting members voting privileges, while associate members could participate without those voting rights.
The question is not whether the NNA was involved. The governing document says it was. The question is how that involvement shaped decisions affecting independent signing agents.
Document: Exhibit A, 2013 Rules and Procedures, Sections 1, 4.1–4.4.
2. The original SPW required $1,000 to join—and $1,000 each year
Sections 4.2.3 and 4.4.3 of the 2013 rules required both regular and associate members to pay a $1,000 joining fee and $1,000 annually. These were workgroup membership fees for qualifying industry participants—not a $1,000 fee imposed on individual signing agents for assignments.
Section 3.3 directed the NNA to keep separate financial records of SPW membership funds received and disbursed. It said membership fees would cover meeting costs, the SPW website, and NNA administrative expenses associated with supporting the workgroup. The membership qualifications also required an NNA industry membership.
What the document establishes: a paid membership structure and NNA financial-recordkeeping responsibilities. What it does not establish: how much was collected, who paid, whether a surplus existed, or what financial arrangements continue today.
This raises a practical question: Who could afford to participate in developing standards, and what opportunities existed for independent notaries to be heard? Paying dues alone does not establish improper influence.
Document: Exhibit A, Sections 3.3, 4.2.1, 4.2.3, 4.4.1 and 4.4.3.
Source Document: View Exhibit A — 2013 SPW Rules and Procedures3. By 2017, the governance rules looked different
The SPW published revised Rules and Procedures in March 2017. That version described an NNA-selected Advisory Committee and gave the NNA express responsibilities involving leadership appointments and amendments to the rules.
The published 2017 rules do not repeat the 2013 $1,000 membership-fee provisions. That does not prove that all dues or financial arrangements ended. It means those particular provisions are absent from that version of the rules.
The next documents worth examining are the records explaining why governance changed, who participated in the revisions, and whether the original membership structure continued in another form.
Documents: Exhibits A and B, 2013 and 2017 Rules and Procedures.
Source Document: View Exhibit B — 2017 SPW Rules and Procedures4. The meeting minutes may tell us who made decisions
Section 5.6 of the 2013 rules required minutes to record the meeting's time and place, regular and associate members present and their affiliations, matters discussed, and actions or votes taken. It required minutes to be distributed with the agenda for the following meeting and approved by regular members.
That is a valuable investigative lead: those records could identify who attended and how specific proposals were considered.
The 2017 Rules and Procedures also contain a provision in Section 5.5.3 requiring prior meeting minutes to be posted on the SPW website.
NNC has not yet obtained or reviewed a complete set of historical meeting minutes or established whether those records are currently accessible.
Documents: Exhibit A, Section 5.6; Exhibit B, Section 5.5.3.
5. The standards are still being updated in 2026
The SPW's August 2026 Background Screening Standards show that the workgroup's requirements are not simply a historical issue. The updated screening framework addresses criminal-record and other checks, disqualification criteria, and a points-based assessment.
Under the published scoring system, an accumulation of 25 points results in disqualification.
The critical questions now are what changed from earlier standards, who approved those changes, and how independent notaries could provide input or challenge inaccurate screening information.
We are not treating the SPW's private standards as federal law.
For the federal oversight context, see Unmasking the NNA — Part 2: CFPB and SPW.
Document: Exhibit C, August 2026 Background Screening Standards.
Source Document: View Exhibit C — 2026 Background Screening StandardsWhat we know—and what we're still investigating
The documents establish that the NNA created the SPW, the original rules required paid membership for qualifying industry participants, the NNA was assigned financial-recordkeeping responsibilities, and the governance model was revised.
They do not establish wrongdoing, total dues revenue, or that membership payments purchased particular decisions.
NNC's next questions concern the historical membership roster, meeting minutes, the rationale for the 2017 changes, and the development and approval of the 2026 screening standards.
Independent notaries deserve to know how standards affecting their ability to obtain assignments are developed—and who participates in making those decisions.
Original Documents & Supporting Evidence
- Exhibit ADecember 2013 SPW Rules and ProceduresView Original PDF
- Exhibit BMarch 2017 SPW Rules and ProceduresView Original PDF
- Exhibit CAugust 2026 Background Screening StandardsView Original PDF
- Exhibit DOriginal Certified Signing Specialist StandardsView Original PDF
- Exhibit EOriginal Certified Signing Specialist ExaminationView Original PDF
- Exhibit FOriginal Certified Signing Specialist Code of ConductView Original PDF
- Exhibit GOctober 2013 SPW AnnouncementView Original PDF
Research note: The National Notary Coalition distinguishes documentary findings from questions requiring further investigation. Private workgroup standards are not, by themselves, federal or state laws.
Awareness • Advocacy • Transparency
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