Notary Signing Agent Document FAQ: USA PATRIOT Act CIP Forms

NSA Patriot Act CIP forms with the National Security Agency seal — Click the image to see the form.

Updated 7-15-24. Signing Agents must deal with a wide variety of different documents during a loan signing, and many of them come with particular or unusual instructions. In this article, we answer frequently asked questions about the USA PATRIOT Act Customer Identification Program Form.

What is the purpose of the USA PATRIOT Act CIP Form?

Signed into law in 2001 in the wake of the 9/11 terror attacks, the U.S. PATRIOT (Providing Appropriate Tools Required to Intercept and Obstruct Terrorism) Act established measures to prevent, detect and prosecute persons engaging in money laundering and terrorism. In 2003, regulations to implement Section 326 of the Act required all financial institutions to establish a Customer Identification Program (CIP) for identifying all new account holders. This requires banks and other lending institutions to have a written procedure in place to establish the identity of customers, including home loan borrowers.

Because Notary Signing Agents must already positively identify borrowers during a loan document signing to execute acknowledgments on a mortgage or deed of trust, Signing Agents are often asked to complete a USA PATRIOT Act CIP form to certify the NSA properly identified the borrower at the signing appointment. Completing this form helps financial institutions, including the nation’s mortgage lenders, to fulfill their PATRIOT ACT regulatory obligations.

Are there other terms for a USA PATRIOT Act CIP Form?

Yes. It may be included in a loan package under other names, such as “Verification of Customer Identity,” “PATRIOT Act Information Form,” or “PATRIOT Act Disclosure — Borrower Identification,” among others.

What types of loan document packages include a USA PATRIOT Act CIP Form?

These forms have been regularly included in various types of loan packages since 2003.

Does a USA PATRIOT Act CIP form require notarization?

No, it does not. However, because a Notary Signing Agent is present at the loan signing involving a lender’s loan, the NSA represents the lender in obtaining the information required in the form.

What information is required to complete a typical PATRIOT Act form?

Typically the Signing Agent will be asked to complete the following information on the form:

The name of the borrower(s), along with other information such as the borrower’s date of birth, Social Security number or tax ID number.
Information about any identification documents used to verify the borrower’s identity, such as the type of ID, the ID identification number, and the date of issuance and expiration for the ID. Some forms may also ask the NSA to include the state or organization that issued the ID.

David Thun is the Editorial Manager at the National Notary Association.

Notary Signing Agent Document FAQ: Signature and name affidavits

Additional Resources:

The Notary Signing Agent’s Loan Documents Sourcebook

44 Comments

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LaWanda

06 Sep 2024

As a Notary Public, I am seeking clarification on whether I should sign the Patriot Act document in Georgia. Since Georgia does not permit notaries to become signing agents, I am uncertain if an attorney is required to complete the form because can not say that I am a signing agent.

National Notary Association

09 Sep 2024

Based on what you’ve described, we think it would be best if you contacted our Hotline team by phone and spoke to them directly about the situation. The NNA Hotline: 1-888-876-0827 Mon – Fri: 5:00 a.m. – 7:00 p.m. (PT) Saturday: 5:00 a.m. – 5:00 p.m. (PT) If you’re not an NNA Member or Hotline Subscriber, they will provide you with a one-time courtesy call.

Yolanda Barajas

13 Aug 2024

In Texas, is a notary allowed to notarize a DocuSign document?

Based on what you’ve described, we think it would be best if you contacted our Hotline team by phone and provided them with a more detailed description of the situation. The NNA Hotline: 1-888-876-0827 Mon – Fri: 5:00 a.m. – 7:00 p.m. (PT) Saturday: 5:00 a.m. – 5:00 p.m. (PT) If you’re not an NNA Member or Hotline Subscriber, they will provide you with a one-time courtesy call.

David V Fuentes, GRI

03 Aug 2024

It’s kind of a contradiction not to sign the Patriot Act form in the capacity of Notary Public; the entire loan signing packet is completed by the signers and the notary. It is ONE loan signing packet or set of documents assigned to a Notary Loan Signing individual. It’s like separating the work of an individual and the the notary stoping him/ her from doing his/her job.

Jaquel M.J.

29 Jul 2024

Positive update; information ℹ️ always needed for reminder to keep agent updated and informed . Thank you 🙏 Namaste

James

Are there any standard rules for the inclusion of a non borrowing spouse in the CIP reporting done by a NSA?

Spencer A Butcher

There seems to be several different variations of the form being used to include and in-house generated form that I've seen. Also, does anyone know why the form requires 2 forms of ID and other times (most the time) 1 form of ID is requested?

Susan Weathers

18 Jul 2024

Form 8300 irs.gov came to my mind when reading these comments.

David Towers

18 Mar 2024

I recently had one of my vendors require me to print my name and title by hand rather than use the special stamp I prepared and have been using for several years with many vendors including them, with my NAME and CNSA as my title. Has anyone else had this issue?

Patricia Tyler

05 Jan 2023

(FL) When I was a New NSA, I had some Title companies demand that I sign the PAT ACT as "Notary Public" or else it would be considered an error and fee withheld. I called the hotline (2.5 years ago) and discussed this conundrum. I was advised to sign as "Notary Signing Agent " just to have that title in it. I've been doing that since and have never had a problem. The other form that asks you to notarize your Signature is the Customer ID form. It has a place for my signature, Commission ID/expiration, my E&O information and Insurance carrier. I have NEVER stamped my Seal! I called Title and alerted them to the FL Statute I'd be violating. They back off. I also agree with all of you that pointed out outrageous requirements from Lenders (THE WORST) and Title companies. I'm not afraid to call them and quote statute, along with an invitation to call the NNA hotline. Many of them say that other Notaries are doing it and I let them know that THIS Notary follows Florida statute. They leave me alone and praise my knowledge.

Rhonda L

02 Jan 2023

I wish the NNA would reach out to the Title Company that require a Notary to complete a Patriot Act for a NON-BORROWER. The form is specifically for Borrowers - NOT NON-BORROWERS, I lost a Vendor because their employee kept insisting, I complete the form for the non-borrower, showing their SS# and driver's license info. That is a violation of the Privacy Act and I will not break the law because of the employees ego. When I advised him to read the form and even pointed out that the form is for a person obtaining a loan only, he blacklisted me and refuses to use me.

S. Miller

06 Nov 2022

In response to the comment from Elijah Echiribel, some of the services you listed are not allowed to be provided by notaries, e.g., preparation of a power of attorney or corporate documents. Maybe you are providing these services in some other role or capacity such as a consultant, etc., but you should not be using the notary title for these services.

Shanece T.

21 Oct 2022

Regarding loan signings, when completing the Patriot Act Form, can the signer provide a copy of their social or green card to satisfy the 2nd ID requirement? Can the 2nd ID be a copy on their computer?

13 Dec 2022

When completing the Patriot Act form, only specific forms ID that are listed on the form should be used. A copy of the ID on their computer cannot be used.

pinpointmn1@gmail.com

16 May 2022

As the signing agent should I be signing on the line titled "Lender"?

18 May 2022

Monika

30 Mar 2022

Do we need to physically see their Social security card or can we just use their SSN as seen on their loan docs, since they have already confirmed that the information is correct?

22 Apr 2022

The USA Patriot Act requires all financial institutions to obtain, verify and record information that identifies every customer. Completion of this documentation is required in order to comply with the USA Patriot Act. A completed copy of this information must be retained with the loan file. Since the information must be “verified’ the original ID document should be review and recorded on the document.

Wendy Campbell

20 Dec 2021

In response to the comment from Elijah Echiribel, I completely disagree that we "don't change hats in the middle of a loan signing". We absolutely do "change hats"; that is precisely the role of a Signing Agent in that we are more than just a Notary Public. I have completed 1000's of loan signings since the Patriot Act became effective and have always used the title "Signing Agent" when completing that form and it has NEVER been rejected.

vistamobilenotary@gmail.com

14 Dec 2021

How do you fill out the patriot act form if you are using credible witnesses instead of a Government ID?

13 Jan 2022

You would have to check with the lender. If the lender is okay with the signer using credible witness, you should then ask the lender how they want you to handle the Patriot Act form.

johnson.k.5127@gmail.com

31 Aug 2021

In the article where it states "The Signing Agent must sign a statement (under penalty of perjury on some forms) that the Signing Agent viewed and accurately recorded the borrower’s identification information and has reasonably confirmed the borrower’s identity." where does the NSA get said statement? Does the statement come included in the Loan Docs package?

29 Sep 2021

Hello. Yes, it should be part of the form, typically directly above where the NSA has to sign.

Tt Jenkins

07 Aug 2021

If the signature line on a Patriot Act form has the escrow officer’s name printed on it but I’m the signing agent who fills out the ID form, who’s responsible for signing it.

12 Aug 2021

Kelsy Woodard

12 Jul 2021

Since the instructions call for 2 forms of ID, would you communicate that to the borrower prior to beginning the loan signing so that they have both readily available? And is one also required for the co-borrower?

03 Aug 2021

Yes, it is recommended that you discuss any ID or other documents the borrower may need to provide at the time of signing. This applies to the co-borrower as well.

Elijah Echiribel

14 Apr 2021

Honestly this is not true on all aspects. You do not change hats in the middle of a loan singing, you are certified and bonded with your states as a Notary Public, not a Loan Singing Agent, that is just a certificaion that you can obtain, Most All Lenders Escrow and Signing Service do not care if you are a LSA. You should not be telling Notaries to sign with Signing Agent after their name as Most will be rejected by the lender on forms such as the Patriot Act. Your are not performing a notarial act when you fill out an ACK or Jurat. With that said.... Notarial services generally include: • attesting the signature and execution of documents • authenticating the execution of documents • authenticating the contents of documents • administration of oaths and declarations • presenting bills of exchange for acceptance and payment • attending upon the drawing up of bonds • providing documents to deal with the administration of the estate of people who are abroad, or own property abroad • authenticating personal documents and information for immigration or emigration purposes, or to apply to marry, divorce, adopt children or to work abroad • verification of translations from foreign languages to English and vice versa • provision of notarial copies • preparing and witnessing powers of attorney, corporate records. • authenticating company and business documents and transactions This includes Authenticating or certifying the singers Form of ID's

Cindy Krah

07 Apr 2021

Are NSA’s required to complete the patriot act on a co-borrower whose husband signed for her as attorney in fact? She was not present at the signing.

08 Apr 2021

Thomas Flynn

31 Mar 2021

What is a qualifying "Organizational Membership Card"? Is there mores in depth training on this form you are aware of?

01 Apr 2021

Hello. An example of an organization that issues an ID would be a state motor vehicle department issuing a driver's license.

Jonathan

14 Mar 2021

How do I complete this form when the signer has no valid form of ID? Shouldn't the loan officer or the title company have addressed this issue when the borrower/signer applied for the loan/refi?

15 Mar 2021

Hello. If you encounter a situation where a signer has no satisfactory proof of identity for a loan signings, you should contact the lender, loan office or signing service to request instructions.

Keith

28 Feb 2021

You are correct. I've never come across a lender requiring this doc to be notarized. Perhaps a solution could be to have the borrower sign the Patriot Act document and then you notarize it?

P. Boger

25 Feb 2021

I just did a signing for a HI property. WIth Guaranteed Rate as the Lender - The lender is threatening to not complete the transaction because I am not able to notarize my own signature on the Patriot Act Form. This was a $200 fee for me - and a significant loss of money for me for time & printing. I just don't understand how the lender can be upset that I can't notarize my own signature on the patriot act form. Has anyone else run into this before? To add to the weirdness of this - the lender had added a (seal) and My Commission Expires line on the document with a type writter (from what I could tell). Please tell me I am not insane for not being able to notarize my own signature. I did offer to apply my stamp and then line through it - so that it wasn't a valid seal. Thanks for any help or comments.

Dawn

23 Dec 2020

I am pleased to see this article. I questioned this form on my 1st loan signing. I had the client sign instead of me after I added their id's.

Ardel Richter

22 Dec 2020

Many of these forms require that the NSA add their title. Some request that the notary use 'Notary Public' as their title. What does the NNA recommend?

05 Jan 2021

Hello. We recommend NOT to use the title “Notary Public” on this form. This is because when an NSA complete this form, he/she is not doing in the capacity as a Notary. As such, the title “Notary Public” should not be used, and should only be used when completing an authorized notarial act.

Theodora

21 Dec 2020

Which is the preferred title used when signing the Patriot Act? Is it Notary Public, Signing Agent or Notary Signing Agent?

Audra Odom

thanks for the useful information...

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