RegTech and Compliance · 12 July 2026 · 6 min read
Third-Party Signatories Inside a Documentation Engagement
Where a third-party signatory signs documents on the client's behalf, the file records the authority, the scope, and the date each signed document is added.

Documentation engagements sometimes operate alongside a third-party signatory: a power of attorney holder, a corporate secretary, or a family member acting under a documented authority. The file records the authority itself as a primary record rather than treating signed documents as if the client had signed them in person.
The authority document is named, dated, and described in plain language. A power of attorney's specific permissions, a corporate authority's named scope, or a family appointment's stated limits are extracted into a short summary that sits at the front of the file so a reviewer does not have to read the underlying instrument to understand what the signatory can and cannot do.
Each document signed by the third party carries a reference back to the authority. The reference identifies the authority by its name and date, so that a later question about the signatory's standing can be answered without re-reading the entire authority chain to confirm the linkage between the act of signing and the basis for it.
Where the authority is time-bound, the file records the expiry date and triggers a refresh well before that date. A signature collected after the authority expired is recorded as an open item rather than silently treated as valid, and the engagement does not backfill an expired authority with a later replacement that did not exist at the time of signing.

Where the authority is limited in scope, the file records the boundary. A power of attorney that covers banking but not investment, or a corporate authority that covers operational matters but not statutory filings, is described against its limits, and any signed document near the boundary is reviewed for whether it falls inside or outside the authority's reach.
Conflicts between the signatory and the principal are screened. Where the signatory's interests could diverge from the principal's, the conflict is recorded, the affected document is flagged, and the engagement may decline to accept a signed document where the conflict materially undermines the document's evidential weight in the counterparty's likely review.
Revocation of authority is handled as a discrete event. Where the principal revokes the third party's authority during the engagement, the file records the revocation date and the operator who confirmed it, and no further document signed by the third party is accepted into the file without a new authority being established and recorded.
Our scope is to maintain the signatory record alongside the documents themselves. We do not draft powers of attorney, do not adjudicate disputes over the validity of an authority, and do not represent the principal in any forum addressing a signatory's conduct. The deliverable is a file in which every signature is traceable to a documented basis.
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