Firms must also consider any related requirements set out in the Principles for Businesses and general rules in the FCA Handbook. In particular, firms should consider:
- Principles 2, 3 ad 6 and review the risks and harms of using electronic signatures, and take appropriate steps to minimise them; and
- The client’s best interests rule (COBS 2.1.1R) and the fair, clear and not misleading rule (COBS 4.2.1R) - where a client signs a document electronically - to ensure that this does not make it more difficult for the client to understand what they are agreeing to.
Link to related article: https://www.fca.org.uk/news/statements/expectations-wet-ink-signatures-coronavirus-restrictions
