7.4 RON Procedures and Recording Requirements

The Audiovisual Recording Requirement

The defining procedural obligation of RON is the audiovisual recording. The notary must create an audiovisual recording of the performance of the notarial act and retain it. "The performance of the act" means the recording captures the whole event — not just the signature. Practically, recording should begin at the start of identity verification and continue through the completed act, so the file shows that every safeguard was followed.

Retention Period — 10 Years

The recording must be retained for at least 10 years after its creation, unless the Department of State establishes a different period by regulation. This is a frequently tested number: not 5, not 7 — 10 years minimum.

Who May Hold the Recording

The notary does not have to store the recording personally. RULONA expressly allows a third party — such as the RON platform or a designated repository — to retain the recording on the notary's behalf. The important caveat is that delegation does not transfer responsibility.

If a third-party vendor loses the file or goes out of business, the notary is still accountable for the missing record. A prudent notary keeps an independent backup or confirms the vendor's retention guarantees.

Certificate and Seal in a RON

The notarial certificate for a RON must state, in addition to the ordinary certificate contents, that the act was performed by means of communication technology. This wording signals to anyone relying on the document that personal appearance was satisfied remotely, not in person.

Example language: "This notarial act involved the use of communication technology."

The venue on a remote certificate is the county where the notary is physically located when performing the act. The notary must be in Pennsylvania; the signer may be elsewhere (57 Pa.C.S. §§ 306.1, 315(a)(2)(iii)).

The notary's electronic signature and electronic seal must be attached to or logically associated with the electronic record and must be tamper-evident, so that any later change to the record is detectable. The electronic seal carries the same identifying information required of a physical stamp — the notary's name, the words "Notary Public," the county and Commonwealth, and the commission-expiration date.

Step-by-Step RON Procedure

1. Establish the session on an approved platform; confirm clear two-way sight and sound and begin recording.
2. Verify identity using personal knowledge, a credible witness on oath/affirmation, or two identity-proofing processes (credential analysis + dynamic KBA).
3. Confirm the signer is aware of the act and acting willingly, and present the electronic record for review.
4. Administer any oath or affirmation required for a jurat/verification on the record.
5. Witness the electronic signature being applied during the live session.
6. Complete the certificate, including the communication-technology statement, and attach the tamper-evident electronic seal and signature.
7. Make a journal entry noting the remote method, the identity-verification method used, the technology/provider, and where the recording is stored.
8. Ensure the recording is saved and retained for at least 10 years.

Records With Their Own Signing Rules

Vehicle titles are the classic example of a record with its own rules. Under 75 Pa.C.S. § 1111(a), the seller's assignment on the certificate of title is sworn to before a notary public or other officer (or verified by an authorized dealer or issuing agent), and PennDOT's fact sheet requires the seller and buyer to sign the paper title in the presence of an authorized PennDOT agent; a title held electronically by a lienholder must first be replaced by a paper title. RULONA does not mention vehicle titles, so follow PennDOT's in-person process.

RON-Specific Journal and Recordkeeping

A RON act produces two parallel records that must both be preserved: the audiovisual recording and the notary's journal entry. They serve different purposes. The recording is the visual proof that the ceremony happened correctly; the journal is the chronological log the notary can search and certify from. A RON journal entry should capture everything an in-person entry captures — date and time, type of act, type of record, and the name and address of the signer — plus three RON-specific facts:

Keeping these aligned matters because, if a RON is ever challenged, the journal points investigators to the specific recording that proves the act was proper. A journal entry with no retrievable recording — or a recording with no journal entry — leaves a gap that undercuts the notarization's evidentiary value.

Exam Focus

• Record the entire act; retain the audiovisual recording at least 10 years.
• A third party may retain it, but the notary stays responsible.
• The certificate must state the act was done by means of communication technology.
• Seal and signature must be tamper-evident; vehicle title transfers follow PennDOT's in-person signing rules.