
This Form Must Be Completed By Each Controlling Person As Defined In Section 91
Use a This Form Must Be Completed By Each Controlling Person As Defined In Section 91 template to make your document workflow more streamlined.
What this controlling-person form does
This form records information and signatures from each controlling person identified under its Section 91 instructions. Because the supplied name does not state an issuing agency, field list, filing deadline, or statutory definition, confirm those details in the source document before completion. In signNow, upload the form, review automatically detected fillable fields, add or correct fields, assign each controlling person, send the document, and retain the completed PDF with its certificate and audit trail. ESIGN and applicable state law govern electronic execution when their conditions are met.
Who completes the named form
Regulated organizations
Organizations named in the Section 91 instructions can use this workflow to collect separate responses and signatures from every controlling person without merging identities.
Compliance departments
Compliance teams can preserve signer-specific evidence for internal review, provided the source document permits electronic execution and the organization follows its retention policy.
Who benefits from this form workflow
The workflow suits organizations that must identify, document, and obtain signatures from each controlling person named by their governing Section 91 instructions.
A small U.S. business can send the form to each controlling person separately, preserving individual responses and a consolidated audit trail without exchanging paper copies. A regulated healthcare organization can route the form through a HIPAA-compliant workflow when protected health information appears, using a BAA and restricted access controls. An enterprise compliance department can use templates, role-based access, and delegated sending to collect the same controlling-person form across subsidiaries while preserving signer-specific evidence.
These tasks are executed by both individual contributors and centralized administrators depending on organizational policy and required controls.
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Complete the controlling-person form
Use the source document provided by the responsible organization, verify every controlling person’s fields, and preserve the completed record with its audit evidence.
Upload form:
Upload the exact form source file. Check fields:
Review detected fields and add missing signer fields. Assign signers:
Assign each controlling person as a signer. Complete record:
Send, monitor completion, and download the record.
Review the signNow audit trail
The audit trail records evidence around each controlling person’s signing event rather than replacing the form’s substantive instructions or legal requirements.
Authenticate signer:
Capture timestamp:
Protect document:
Seal history:
Verify evidence:
Export trail:
Configure a controlled signing workflow
Configure identity checks, signature capture, audit evidence, retention, encryption, and user access before sending this controlling-person form.
| Setting | Recommendation |
|---|---|
| Authentication method | Email verification with SMS OTP |
| Signature type | Typed, drawn, or uploaded signature |
| Audit trail | Retain completion certificate and activity log |
| Document retention | Apply the governing record schedule |
| Encryption | AES-256 at rest and TLS 1.2/1.3 |
Protect signed form records
Transport encryption:
Stored encryption:
SOC 2 Type II:
ISO 27001:
Electronic signing:
HIPAA workflows:
Features for controlling-person forms
signNow connects field preparation, signer assignment, electronic signatures, audit evidence, and controlled storage for organizations collecting this named form.
Field review
Upload the supplied form and inspect signNow’s detected fields before assigning each controlling person. This reduces omissions caused by relying on an unreviewed automated field layout.
Signer routing
Assign separate signer roles so every controlling person completes the information intended for that person. Routing rules keep the signing sequence visible when multiple people must participate.
Signature capture
Capture typed, drawn, or uploaded signatures with signer actions and timestamps. The resulting record connects the completed form to the signing event for later review.
Reusable template
Use templates when the organization repeatedly sends the same Section 91 form. Shared templates reduce reconfiguration while administrators control who can edit or send them.
Record control
Keep the signed document and completion certificate together with restricted access. This creates a clearer evidence package when the organization reviews the form later.
Flexible delivery
Let controlling persons sign through web or mobile workflows. The organization can send a signing link when direct email routing is not suitable for the collection process.
Legal standing of electronic records
For a business record, an electronic signature on this form may carry the same legal effect as a handwritten signature when the signer demonstrates intent, consents to electronic records, can be attributed, and the record remains reproducible under ESIGN, 15 U.S.C. chapter 96, and applicable UETA or New York ESRA rules. ESIGN exceptions include wills, codicils, testamentary trusts, court orders, and specified family-law documents.

Troubleshoot form completion issues
Resolve field assignment, signer identity, electronic-consent, retention, and plan-feature questions before relying on a completed controlling-person record.
The form title does not identify an issuing agency or governing statute. Confirm the source document, instructions, and controlling-person definition before uploading it to signNow. The platform can route and record signatures, but it does not determine which people legally qualify under Section 91.
Upload the original document, then inspect signNow’s detected fields before sending. Add or correct fields when the source PDF contains labels that cannot be reliably detected. Confirm that each controlling person receives only the fields intended for that person.
Use separate signer roles for each controlling person and assign fields by role. Review the routing order before sending. A completed audit trail can show actions and timestamps, but it cannot cure a missing required signer or inaccurate identity information.
SignNow supports electronic signing under ESIGN and UETA when intent, consent, attribution, and record retention requirements are satisfied. For consumer-facing records, provide the ESIGN disclosure and confirm electronic access before requesting a signature.
Keep the completed form, certificate of completion, and activity history together. The correct retention period depends on the organization’s governing rule and the form’s purpose; do not substitute signNow’s storage period for a legal retention schedule.
Business includes audit trails, templates, and mobile apps. Business Premium adds bulk send and kiosk mode, while Enterprise adds advanced signer authentication. Select the plan based on the required workflow rather than assuming every feature is included.
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