Cross-Media Electronic Reporting Rule

Lesson 6: Signature Validation

Checklist items 13 through 17 are grouped under the Signature Validation Process, and represent CROMERR requirements that the system must satisfy as part of ensuring that electronic signatures it receives are valid.

Select each item under the Submission Process to learn more.

13. Credential Validation
For each electronic signature received, CROMERR requires that the system verify that the identified signer is actually authorized to sign the submittal.
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14. Signatory Authorization
Under the Submission Process, CROMERR requires that the system be able to flag counterfeit submittals. Under the Signature Validation Process, CROMERR also requires that the system be able to flag counterfeit credential use, which would indicate that the credential has been compromised.
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15. Procedures to Flag Counterfeit Credential Use
CROMERR requires that the system include procedures to follow up on evidence and reports of credential compromise, including procedures to revoke a credential when compromise is indicated. Correspondingly, the system must be able to reject submissions that include e-signatures executed with revoked credentials.
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16. Procedures to Revoke or Reject Compromised Credentials
CROMERR requires that the system include procedures to follow up on evidence and reports of credential compromise, including procedures to revoke a credential when compromise is indicated. Correspondingly, the system must be able to reject submissions that include e-signatures executed with revoked credentials.
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17. Confirmation of Signature Binding to Document Content
Related to item 5—requiring signature binding—CROMERR requires that the system be able to determine whether the content of an electronically-signed submittal matches the content at the time the signature was executed.
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- Review the Regulation Language: § 3.2000(b)(5)(ii)

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Valid Electronic Signature

Valid electronic signature refers to an electronic signature on an electronic document that has been created with an electronic signature device. The identified signatory is uniquely entitled to use the signature device for signing that document provided that this device has not been compromised, and where the signatory is an individual who is authorized to sign the document by virtue of his or her legal status or his or her relationship to the entity on whose behalf the signature is executed.

Electronic Signature Device

Electronic signature device refers to a code or other mechanism that is used to create electronic signatures. Where the device is used to create an individual's electronic signature, then the code or mechanism must be unique to that individual at the time the signature is created and he or she must be uniquely entitled to use it. The device is compromised if the code or mechanism is available for use by any other person.

Review the Regulation Language: § 3.2000(b)(5)(i)

(b) An electronic document receiving system that receives electronic documents submitted in lieu of paper documents to satisfy requirements under an authorized program must be able to generate data with respect to any such electronic document, as needed and in a timely manner, including a copy of record for the electronic document, sufficient to prove, in private litigation, civil enforcement proceedings, and criminal proceedings, that... (5) In the case of an electronic document that must bear electronic signatures of individuals as provided under paragraph (a)(2) of this section, that: (i) Each electronic signature was a valid electronic signature at the time of signing

Review the Regulation Language: § 3.2000(b)(5)(ii)

(b) An electronic document receiving system that receives electronic documents submitted in lieu of paper documents to satisfy requirements under an authorized program must be able to generate data with respect to any such electronic document, as needed and in a timely manner, including a copy of record for the electronic document, sufficient to prove, in private litigation, civil enforcement proceedings, and criminal proceedings, that... (5) In the case of an electronic document that must bear electronic signatures of individuals as provided under paragraph (a)(2) of this section, that: (ii) The electronic document cannot be altered without detection at any time after being signed

Cross-Media Electronic Reporting Rule

Lesson 6: Signature Validation

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Valid Electronic Signature

Electronic Signature Device

Review the Regulation Language: § 3.2000(b)(5)(i)

Review the Regulation Language: § 3.2000(b)(5)(ii)

Cross-Media Electronic Reporting Rule