The workflow should not be marketed as suitable for every document that can physically hold a signature. 15 U.S.C. § 7003 excludes or carves out important categories, including wills and testamentary trusts, adoption and divorce matters or other family-law matters, court orders and notices, official court documents, cancellation or termination of utility services, default or acceleration or repossession or foreclosure notices for a primary residence, cancellation or termination of health or life insurance benefits, product recall or material-failure safety notices, and hazardous-material transport documentation.
15 U.S.C. § 7003 also excludes the Uniform Commercial Code other than sections 1-107 and 1-206 and Articles 2 and 2A. In practical product terms, that means DullyPDF should not present the ordinary self-serve signing workflow as the compliance answer for negotiable instruments, bank collection items, funds transfers, letters of credit, documents of title, investment securities, or secured transaction records simply because they can be rendered as a PDF. Those areas need their own legal analysis and often their own specialized operational controls.
Notarization, acknowledgment, witness, or filing regimes are another separate category. 15 U.S.C. § 7001(g) addresses notarization and acknowledgment requirements, and New York adds specific real-property recording rules in 9 NYCRR Part 540 and N.Y. Real Prop. Law § 291-i. DullyPDF can support ordinary signing workflows, but it is not a blanket replacement for remote online notarization, county recording systems, or witness-managed execution programs.
- Keep out: wills, codicils, and testamentary trust instruments under 15 U.S.C. § 7003(a)(1).
- Keep out: adoption, divorce, and other family-law records under 15 U.S.C. § 7003(a)(2).
- Keep out: court orders, pleadings, official notices, and service-bound court records under 15 U.S.C. § 7003(a)(2).
- Keep out: primary-residence foreclosure, eviction, utility shutoff, certain insurance cancellation, and safety or hazmat notices under 15 U.S.C. § 7003(b).
- Separate review required: excluded UCC records outside sections 1-107, 1-206, and Articles 2 and 2A under 15 U.S.C. § 7003(a)(3).
- Separate program required: notarized, acknowledged, witnessed, or recorded instruments.