This document discusses legal and compliance considerations for delivering transactions and obtaining signatures on mobile devices. It addresses the need to meet legal requirements, obtain informed consent, and properly manage records. Key requirements include obtaining consent for electronic delivery, ensuring the full document is displayed, allowing retention of copies, and tracking authentication, storage, and transmission of records. The design process for mobile apps must consider issues like version control, online/offline operation, security, and special deployment concerns to properly deliver records and signatures.

1. Taking Transactions Mobile R. David Whitaker Senior Company Counsel Strategy and Operational Risk Group Wells Fargo Bank, N.A. November 9, 2011

4. Baseline – Delivering Disclosures and Signing Agreements – The Record Management Cycle Secure Communication Record Management Responsibility Generate Deliver Store Manage Destroy Record Life Cycle Propagate Data Track Record Versions Extract & Index Data Create Audit Trails & Reports Secure and Consistent Record Management Active Data Processes Access Controls Quality & Integrity Controls Record Destruction Business Continuity Key Systems Issues Boilerplate Docs Transaction-specific Docs Audit Trails for Enrollment, Delivery/Signing Screen Shots & Process Flows Primary Record Categories Search and Report Capabilities Company Policies and Guidelines Record Management Audit Trails & Reports

6. Delivering Records and Obtaining Signatures – General Signature Strategy on a Mobile Device Offline Or Online? Assure all signature elements addressed – Intent, Attribution, Authority Present record in full-screen display, Using a series of screens, if necessary Email for retention or obtain agreement and provide online retention copy Get Consent Present Document Obtain Signature Deliver Retention Copy