eNotes, eVault, and eClosings on BlueNotary

BlueNotary is a Remote Online Notarization (RON) and eSignature platform. This article explains what that covers, and clarifies a common question: whether BlueNotary handles eNotes, eVaulting, or MERS eRegistry. The short answer is that we don't; and below we explain exactly what that means for your closings.

Does BlueNotary support eNotes?

No. BlueNotary does not create, store, or manage eNotes (electronic promissory notes) as transferable records. We are a RON and eSignature platform: we enable documents to be signed electronically and notarized remotely by a commissioned notary over a secure audio-video session.
An eNote is a specialized instrument. To function as a legally controlled electronic note, it must be maintained as a "transferable record" under UETA §16 and E-SIGN §201 (15 U.S.C. §7021) held as a single authoritative copy that is unique, identifiable, and unalterable, in a system that reliably establishes who the note was issued or transferred to (the controller). The person with control is treated as the holder of the note. That control function is performed by an eVault, which BlueNotary does not provide.

Does BlueNotary offer an eVault?

No. We do not operate an eVault and are not the system of record for control or holder status of any electronic note. We do not maintain the authoritative copy of a transferable record, and we cannot issue documentation establishing control, holder status, or transfer of an eNote.

Is BlueNotary integrated with MERS eRegistry?

No. BlueNotary is not integrated with the MERS eRegistry. Because we do not vault eNotes, there is no controlled electronic note to register or transfer through MERS.

Can I still do a loan closing on BlueNotary?

Yes – as a hybrid eClosing. In a hybrid closing, most documents are signed and notarized electronically through BlueNotary, while the promissory note is signed on paper (wet-signed) rather than as an eNote. This is one of the most common eClosing types in the market and is accepted for loans that do not require a fully digital eNote.

What you can do on BlueNotary:

• Electronically sign the closing package (excluding the note as an eNote)
• Have signatures notarized remotely via compliant RON
• Receive a completed, notarized document set with the notarization audit trail for the session

What happens outside BlueNotary:

• The promissory note is wet-signed on paper, or handled as an eNote in a separate eVault you or your lender maintains
• Control, holder status, and secondary-market registration (MERS eRegistry, GSE delivery) are established in that eVault, not on BlueNotary

I need to sell or pledge the note on the secondary market. Can BlueNotary help?

Not directly. Selling, pledging, or registering an eNote requires that the note exist as a controlled transferable record in a qualifying eVault. Because BlueNotary does not provide eVault or eNote services, the note must be established and maintained in an eVault to support secondary-market delivery.
If you already work with an eVault provider, BlueNotary can be used for the RON signing portion of your closing while control of the note is established in your vault. If you do not yet have an eVault, that capability needs to be in place before an eNote can be controlled, transferred, or registered.

Summary

Are eNotes and eVault on your roadmap?

Yes. We're looking for a launch lender partner. If you're a lender who wants fully digital eNotes and is willing to be an early design partner, you'd get to shape the workflow and move to the front of the line as we complete certification. If that's you, we'd like to talk reach out to our team to start the conversation.
If you have questions about whether BlueNotary fits your closing workflow, or how to combine BlueNotary RON with an eVault you maintain, please contact us.

Sources and references

• 15 U.S.C. §7021 — Transferable Records (E-SIGN Act): Defines a transferable record, the six conditions for "control," and establishes that the person in control is the holder of the note. https://www.law.cornell.edu/uscode/text/15/7021
• Uniform Electronic Transactions Act (UETA) §16: State-law counterpart governing transferable records and control; the person controlling the transferable record is treated as the holder. (Uniform Law Commission)
• Fannie Mae — General Information on eMortgages (Selling Guide B8-8-01): Requires each eMortgage to be evidenced by an eNote that is a valid, enforceable transferable record under UETA/E-SIGN, with full rights of control. https://selling-guide.fanniemae.com/sel/b8-8-01/general-information-emortgages
• Fannie Mae — Requirements for Creating, Closing, and Correcting eNotes (Selling Guide B8-8-02): eNotes must be registered on the MERS eRegistry immediately upon execution and created in MISMO SMART Doc® format. https://selling-guide.fanniemae.com/sel/b8-8-02/requirements-creating-closing-and-correcting-enotes
• Fannie Mae — eClosing Scenarios: Describes hybrid, full eClosing, IPEN, and RON closing types, and notes a borrower is not asked to sign a paper note when an eNote has been signed. https://singlefamily.fanniemae.com/media/22966/display
• Fannie Mae — FAQs: eClosings & eMortgages: Explains that enforcement of eNotes may require a transfer of control in the MERS eRegistry, and that servicers must have access to an eVault integrated with the MERS eRegistry. https://singlefamily.fanniemae.com/learning-center/delivering/faqs-eclosings-emortgages

This article is provided for general informational purposes and does not constitute legal advice. Requirements vary by investor, state, and transaction type; consult qualified counsel for your specific situation.

Updated on: 17/08/2026