Hello,

we would like to start using DocuSign, or accept scanned applications for the PPP. I have reviewed the two documents SBA has released permitting ESIGN, however they require a cumbersome two factor authentication process that we cannot use. Understandably, its impossible to get guidance from the SBA right now.

Do you see any issues with accepting a scanned application vs a wet signature?

It doesn't look like scanned applications would be acceptable based upon this procedural notice.

https://content.govdelivery.com/accounts/USSBA/bulletins/2831009

We are also struggling to determine if we can make Docusign compliant. Has anyone had any success?

This is not workable for you?

all SBA Lenders may accept scanned copies of signed applications and loan documents, provided the SBA Lender also obtains:
1.A copy of the individual’s driver’s license or other valid form of identification (front and back); and
2.A valid original signature on the applicable document within 6 months of the date of the Note.

Hi CosmoKramer - we were able to set up the dual factor authentication in DocuSign (one time code and identity-based questions).

Still waiting on guidance from SBA on signing the note - the Interim Rule alludes to it being ok but is not clear.

We have several wet signed/scanned applications that were submitted over the weekend. Our IT department added DocuSign fields where statements require initials and another signature line. These applications are being re-sent via DocuSign, with ESIGN consent and SMS authentication. We believe this will solve the SBAs requirement.

Probably fine for applications. No word yet on the actual notes.