Digital Signature / e-Notary Integration — impact tolerance ≤ same day — ITOL

Impact tolerance: ≤ same day — any outage spanning a scheduled closing date, for any share of scheduled closings (illustrative default — trace the derivation, then replace with your own harm analysis)

Definition: Integration enabling remote online notarization (RON) and e-signature execution for loan closings and account-opening documents.

Why it is designated: FinCEN's Customer Due Diligence (CDD) Rule requires beneficial-ownership identification at account opening. That capture often runs through the same digital-signature/e-notary workflow as loan closings. One outage therefore stalls closings and CDD compliance at once. Scheduled closing dates drive the same-day tolerance.