Draft MISMO Virginia RON Certification Scope Inquiry

# Draft MISMO Virginia RON Certification Scope Inquiry

Status: draft for review
Date drafted: 2026-05-17
Prepared for: Greg Lirette / Notary Geek / GoodWare LLC

## Purpose

This draft asks MISMO for a written clarification about the scope of MISMO RON certification, specifically whether certification evaluates Virginia state-law identity-method compliance for remote electronic notarizations.

The intended tone is formal, narrow, and source-focused.

## Draft Letter

Greg Lirette  
GoodWare LLC / Notary Geek  
Clearwater, Florida  
G@notary.cx  

[Date]

MISMO  
[Email / Address]

Re: Request for clarification regarding MISMO RON certification and Virginia remote online notarization identity methods

To MISMO:

I am requesting written clarification regarding the scope of MISMO RON certification as it relates to Virginia remote online notarization identity methods.

My question is narrow: does MISMO RON certification determine whether a certified provider's actual workflow satisfies Virginia's statutory identity requirements for a Virginia electronic notarization, especially when the signer is remote, unknown to the notary, outside Virginia or outside the United States, lacks a U.S. Social Security number, or is routed through a biometric, international-signer, or no-KBA workflow?

The reason for this request is that MISMO certification language is visible in the public marketplace and can be read by customers, notaries, title companies, document recipients, and AI systems as a broad trust or compliance signal. In state-specific RON contexts, that can create confusion unless the scope of the certification is stated clearly.

For a Virginia electronic notarization, the question is not only whether a platform is secure, whether the notary is commissioned or insured, whether an audio-video session occurred, or whether a provider displays an industry certification. The transaction-level question is:

Which Virginia statutory satisfactory-evidence method was used for that signer, on that date, and what record proves it?

Virginia Code section 47.1-2 is method-specific. For electronic notarization, it identifies several possible identity paths, including credential analysis, antecedent in-person identity proofing, another method authorized under section 2.2-436, a valid digital certificate accessed by biometric data or a PIV/PIV-I-style credential, and knowledge-based authentication assessment.

Please provide a written response to the following questions:

1. Does MISMO RON certification determine whether a provider's workflow complies with Virginia Code section 47.1-2 for a particular Virginia electronic notarization?

2. Does MISMO RON certification evaluate whether a provider's biometric, selfie, liveness, face-match, international-signer, or no-KBA workflow satisfies Virginia's identity-method requirements?

3. Does MISMO RON certification verify that a provider's biometric workflow maps to Virginia's phrase involving a valid digital certificate accessed by biometric data or a PIV/PIV-I-style credential?

4. Does MISMO RON certification review transaction-level notary records showing which Virginia statutory identity method was actually used in a session?

5. Does MISMO distinguish between platform/security controls and state-law satisfactory evidence of identity in its certification materials?

6. Does MISMO require certified providers to avoid marketing language that could cause readers to treat MISMO certification as a state-law compliance determination?

7. If MISMO certification does not determine Virginia state-law identity compliance, what public wording does MISMO recommend certified providers use to avoid overstatement?

8. If MISMO certification does evaluate Virginia identity-method compliance, please identify the criteria, audit scope, legal authority, and transaction evidence used for that determination.

This issue matters because public RON provider pages may combine MISMO certification language, badge or seal language, secure-platform wording, Virginia e-notary marketing, paid identity-check products, commissioned-and-insured notary language, background-check or E&O trust signals, and out-of-state or overseas signer availability claims. Those signals may all be relevant in context, but they do not by themselves answer which Virginia statutory identity method was used for a specific session.

By way of public example, Remote NotarEZ publicly states that it is MISMO certified, markets Virginia remote notary service for out-of-state and overseas signers, lists paid biometric identity verification / KYC identity verification / credential-analysis checks for independent electronic notaries, and describes Virginia online notary credentials using Virginia approval, NNA background checks, and E&O insurance. I am not asserting in this letter that any specific Remote NotarEZ transaction was unlawful. I am using that public example to illustrate why MISMO's certification scope should be stated plainly: MISMO certification should not be misunderstood as proof that a specific Virginia notary identified or recorded a lawful Virginia satisfactory-evidence method for a particular session unless MISMO actually reviews and certifies that issue.

I previously raised related concerns with title-industry contacts and copied MISMO at info@mismo.org on January 23, 2025. I have also attempted to contact MISMO by phone and email. I am requesting a written response that can be used to accurately describe the scope of MISMO RON certification.

Please confirm whether MISMO RON certification is, or is not, a determination that certified RON providers comply with Virginia notary-law identity requirements for remote electronic notarizations. If the answer is no, please state that plainly. If the answer is yes, please identify the scope and basis for that determination.

Respectfully,

Greg Lirette  
GoodWare LLC / Notary Geek  
G@notary.cx

## Supporting Materials To Attach Or Cite

- Virginia Code section 47.1-2.
- Virginia 2011 SB 827 / HB 2318 enrolled text.
- Notary Geek Virginia biometrics correction memo.
- Remote NotarEZ MISMO FAQ capture.
- Remote NotarEZ Virginia page capture.
- Remote NotarEZ pricing page capture for standalone ID-check offerings.
- Remote NotarEZ Virginia notary credentials FAQ capture.
- MISMO certification/disclaimer materials.
- Prior January 23, 2025 notice history.

## Drafting Guardrails

Keep the first MISMO letter focused on certification scope.

Avoid mixing in separate disputes about title companies, FCRA, antitrust, or specific customer matters unless a separate legal strategy calls for a broader notice letter.

The strongest first question is simple: does MISMO certification include Virginia state-law identity-method compliance review, yes or no?