FCA expectations for wet-ink signatures in light of COVID-19 restrictions

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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.

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