Draft Notice to Vital Records Online Regarding Notary and Identity-Proofing Routing

# Draft Notice Letter to Vital Records Online Regarding Notary and Identity-Proofing Routing

Draft status: preparing for review

Short link:
https://notary.cx/vro-letter

Public dashboard record:
NG-LTR-VRO-NOTARY-IDV-001

## Draft Letter

VRO LLC  
4300 Biscayne Blvd, Suite 302 A  
Miami, FL 33137

Re: Vital Records Online identity proofing, online notarization facilitation, third-party notary disclaimer, and customer-facing compliance routing

To Vital Records Online / VRO LLC:

I am writing to put Vital Records Online on notice of an issue that intersects with online notarization, identity proofing, vital-record application routing, customer disclosures, and downstream apostille/document-use risk.

Your public Terms and Conditions page, last updated July 24, 2025, states in substance that VRO is an authorized third-party provider specializing in preparation and filing of applications for birth, marriage, divorce, and death certificates. The same terms state that identity verification and proofing are conducted using trusted third-party vendors, that in states requiring notarized applications VRO may facilitate online notarization through authorized providers, that where online services are unavailable VRO refers customers to third-party in-person notaries, and that VRO assumes no liability for the services of third-party notaries.

The liability disclaimer is understood. But the disclaimer does not end the inquiry.

VRO is not merely a passive directory if it is collecting customers, preparing applications, determining filing methods, routing identity proofing, facilitating online notarization, referring notaries, operating a customer portal, and representing that submissions meet agency-specific requirements. If VRO routes a customer into a notary or identity-proofing workflow, VRO should be able to explain the workflow, the third-party role, the customer disclosure, the record retained, and the boundary between VRO responsibility, notary responsibility, identity-vendor responsibility, and government-agency responsibility.

The point is not that VRO becomes liable for every act of every third-party notary merely because a referral was made. The point is narrower: a company cannot market, structure, and route a document-compliance workflow while leaving customers unable to tell who selected the notary path, what identity method was used, what records exist, what state law controlled the notarial act, and who answers if the agency, apostille authority, court, or foreign recipient later rejects the document.

This is especially important for vital-record applications because a customer may reasonably believe that the private vendor, the identity check, the notarization, and the government filing are one continuous compliance workflow. A notarized application can also become part of a later apostille, embassy, immigration, passport, banking, family-law, school, or foreign-use document chain. When a private vendor disclaims responsibility for third-party notaries but still routes or facilitates the notary step, the customer and the receiving agency need more clarity than a general limitation-of-liability clause.

I am asking VRO to review and comment on the following:

1. Which online notarization providers, platforms, or notary networks does VRO currently use, facilitate, recommend, or refer customers to?
2. Which states, document types, and agency workflows require notarization in the VRO process?
3. When VRO facilitates an online notarization, what notary state is used, what identity-proofing path is used, and what record does VRO retain?
4. Does VRO distinguish between a notarial act, third-party identity proofing, customer account authentication, and government-agency application review in its customer disclosures?
5. If an online notarization fails, is rejected, is challenged, or later proves incompatible with an agency, apostille authority, or foreign recipient, what responsibility does VRO accept and what responsibility does VRO deny?
6. Does VRO tell customers before payment that blank forms are available for free from government or health-department sources, and that VRO is charging for preparation, identity verification, routing, filing assistance, or related convenience services rather than issuing the vital record itself?
7. VRO states that it is an officially authorized third-party provider for the State of California. Please identify the specific California authorization, agreement, portal, program, or agency relationship that supports this statement and explain whether that authorization extends to notarization facilitation or only to vital-record application handling.
8. Does VRO audit third-party notary providers or RON platforms for compliance with the notary law of the state where the notary is commissioned?
9. Does VRO preserve enough information to answer, after the fact, who notarized the application, what platform was used, what identity method was used, what audio-video or journal records exist, and where those records are stored?
10. Has VRO reviewed whether any customer-facing language could cause customers to believe that online notarization, identity proofing, application preparation, state filing, and certificate issuance are all guaranteed by VRO?

This notice is not a request for private customer data. It is a request for a public or written explanation of the compliance architecture VRO is using when it routes customers through identity proofing and notarization in connection with vital-record applications.

Notary Geek's concern is not that every third-party notary referral is improper. The concern is that private document vendors can create a responsibility gap: the vendor sells the workflow, the identity vendor performs a check, the notary performs a notarial act, the government agency accepts or rejects the application, and the customer may be left unable to determine who was responsible for which compliance step.

Please preserve any records relevant to VRO's notary-provider selection, online notarization routing, identity-proofing vendors, California authorized-provider claim, customer disclosures, and any internal review of notary-related rejection, refund, or complaint issues.

Respectfully,

Greg Lirette  
Notary Geek / Notary.CX  
https://notary.cx