Numbered Memo 2024-04: Absentee Ballot Signature Verification Pilot Program

[Author]¹

This memo explains how selected county boards will carry out an absentee ballot signature verification pilot program for the 2024 primary election as required by Session Law 2023-140 (Senate Bill 747). The pilot program is being conducted for evaluation purposes only and will not affect whether any absentee ballot is counted for the election.²

¹ This memo is issued under the authority delegated by the State Board to the executive director pursuant to G.S. § 163-22(p).

² Session Law 2023-140, Section 48(c).

1. Overview

   The pilot program consists of selected county boards of elections using automated signature verification software to compare the signatures of voters on all executed absentee-by-mail ballots received by the county board in the 2024 primary. County boards shall accept signatures that are determined to be a match by the software. For signatures that are not identified as a match by the software, county boards of elections will conduct a manual review of those signatures to help evaluate the accuracy of the automated software review. County boards will then compile data from the pilot and forward it to the State Board for analysis, and the State Board will report the results of the analysis to the General Assembly.³

2. Sources of Clipped Signature Images

   County boards will begin by comparing the voter’s signature on file in VoterView in SEIMS with the voter’s signature on the absentee envelope. The clipped signature in VoterView will generally be the voter’s most recent signature. This signature is frequently captured using a means of signing other than pen to paper. Sources of clipped signatures in VoterView include:

   • Voter registration forms and updates from registration activity. These signatures may be scanned images from paper forms or digital images from registration activity through DMV. Most voter registration signatures come from DMV, where signatures are captured using a stylus on an electronic signature pad in a DMV office. Signatures received from DMV are typically 200 dpi (dots per inch), and therefore may appear slightly pixelated and bolder. They may also be missing part of the image due to signing on a signature pad.
   • Absentee request forms. The signature may be a scanned image from a paper form or, if the request was made through the State Board’s online absentee request portal, the signature was provided electronically using a mouse or a finger on a touchscreen. Visually impaired voters are permitted to type their signature.
   • Paper or electronic pollbooks and provisional applications. These signatures are scanned images from paper forms.
   • Other sources. Other sources of signatures include National Change of Address (NCOA), confirmation, and verification cards returned by voters with updates.

3. Steps for Signature Comparison

   There are two tiers of review in the process of comparing the voter’s signature on the absentee envelope with the voter’s signature on file:

   1. Tier 1 (automated comparison)
   2. Tier 2 (manual comparison)

   Tier 1 Review

   Tier 1 review is carried out by automated signature verification software, which will have a match sensitivity set by the State Board for all counties participating. If the software determines the voter’s signature on the absentee envelope is a match for the voter’s signature on file, no further review shall occur. The software vendor and the State Board will provide training and other resources to the county boards about how to use the software.

   Tier 2 Review

   If the software is unable to determine that the signatures match, the signature on the absentee envelope will proceed to Tier 2 review. In this step, the county board will conduct a manual review to compare the two signatures and, if needed, review other signatures and information in the voter’s registration record. The county board will then vote on whether the signature on the absentee envelope is sufficiently similar to the signature(s) on file and may be approved. This process occurs in an open meeting.

4. County Board Meetings

   The county board of elections shall schedule an open meeting to review signatures identified for Tier 2 review. All deliberations must be conducted in an open meeting. At least three board members (a quorum) must attend the meeting.⁴ A majority of the board members present at the meeting must vote for an action for it to pass. It is a best practice for board members from both parties to be present at the meeting.

   Staff must research and compile materials, including all of the voter’s previous signatures on file in SEIMS, ahead of time to streamline the county board’s review. As a reminder, county board members are not permitted to access SEIMS.⁵

   In the meeting, county board members will simultaneously compare the voter’s signature on the absentee envelope with the voter’s signature in VoterView. This may be accomplished by preparing individual packets or displaying the signatures on one or more terminals. Regardless of the means of signature comparison that is used, county boards must ensure that members of the public in attendance at the meeting are not permitted to make any copy, tracing, photograph, or recording of the voter’s signatures.⁶

   All decisions by the county board shall be documented in a spreadsheet. The State Board will provide a sample spreadsheet for use by the county boards.

5. Public Records Requests for Signatures

   North Carolina law prohibits any person other than an authorized election official from copying or tracing a voter’s signature.⁷ Voter signatures may be viewed in the county board office. If a member of the public requests access to voter signatures, the county board shall allow the signatures to be viewed in the office, but staff must supervise to ensure that the signatures are not recorded, copied, or traced. As indicated in Protecting Certain Voter and Elections Security Information: Numbered Memo 2022-01, scheduling access to view public records may depend on the availability of staff to supervise the review. The county board need not allow review of signatures during, or immediately before or after a board meeting, if it does not have sufficient staff to do so.

   It is a crime for someone who is not authorized by law to retain a voter’s signature from a submitted voter registration form.⁸

6. Analysis of Signatures

   As mentioned, during Tier 2 review the county board will simultaneously compare the voter’s signature on the absentee envelope with the voter’s signatures in VoterView. The county board may also use the voter’s signature on the copy of their photo ID submitted with the absentee envelope, if an ID was submitted and the ID has a signature. A signature on a photo ID exemption form may not be used since it was signed and submitted simultaneous with the absentee envelope under review.

   When comparing signatures, it is important to keep in mind that everyone writes differently, and no one signs their name exactly the same way twice. A voter’s signature on the absentee envelope should not be rejected just because it does not look exactly the same as the signature in the voter’s SEIMS profile.

   Signature comparison begins with the presumption that the signature on the absentee envelope is the voter’s signature. Again, an exact match is not necessary for the county board to confirm that the signature on the absentee envelope is a valid signature, since a human voter cannot be expected to make a precisely matching signature each time they sign something. Similar characteristics between a signature being compared and any signature in the voter’s record are sufficient to determine that a signature is valid.

   When evaluating signatures, the county board should review using broad characteristics to evaluate an entire signature as a unit, and if needed to confirm a match, they should also focus on specific letters within a signature. For examples and detailed guidance on how to consider broad and narrow characteristics, see the appendix at the end of this memo.

   The county board shall conduct the following analysis when deciding whether signatures are consistent with each other:

   1. Evaluate the Signature’s Broad Characteristics

      Broad characteristics include:

      1. The type of writing (e.g., cursive vs. print)
      2. The amount of care put into the writing (e.g., quick and sweeping vs. slow and detailed)
      3. Overall spacing
      4. Overall size and proportions
      5. Position of the signature (e.g., slanted vs. straight)
      6. Spelling and punctuation

      If the broad characteristics of the signature on the absentee envelope are consistent with the broad characteristics of the voter’s signature on file, the county board shall accept the signature.

   2. Evaluate the Signature’s Local Characteristics

      If the county board finds a combination of dissimilarities between the two signatures’ broad characteristics, then the county board shall evaluate local characteristics, which include:

      1. Internal spacing
      2. The size or proportions of a letter or letter combination
      3. Curves, loops, and cross-points
      4. The presence or absence of pen lifts
      5. Beginning and ending strokes

      After evaluating the signatures’ local characteristics, the county board must decide whether to accept the signature on the absentee envelope as genuine. A county board may not reject a voter’s signature without first comparing it to all of the other voter’s signatures on file in the voter’s SEIMS record.

   3. Explanations for Discrepancies

      If, after going through the above analysis, the county board finds a combination of differences between the signature on the absentee envelope and the signature or signatures in the voter’s record, consider whether the differences can be reasonably explained. If the county board can reasonably explain the differences, the signature must be accepted. Looking at more than one signature from the voter’s SEIMS record, if available, may be necessary because people develop certain signature habits over time. Identify these habitual marks and determine whether they exist in the signature on the absentee envelope.

      The county board shall consider the following as possible explanations for discrepancies in signatures:

      1. Evidence of trembling or shaking in a signature could be health-related or the result of aging.
      2. The voter may have used a diminutive of their full legal name, including, but not limited to the use of initials, or the rearrangement of components of their full legal name, such as a reversal of first and last names, use of a middle name in place of a first name, or omitting a second last name.
      3. The voter’s signature style may have changed over time.
      4. The voter’s signature on the absentee envelope or registration form may have been written quickly.
      5. A signature in the voter’s record may have been written with a stylus pen or other electronic signature tool that may result in a thick or fuzzy quality.
      6. The surface of the location where the signature was made may have been hard, soft, uneven, or unstable.
      7. Factors applicable to a particular voter, such as the age of the voter, the age of the signature(s) contained in the voter’s record, the possibility that the voter is disabled, and the quality of any digitized signature(s) contained in the voter’s record.

      Only a signature possessing multiple, significant, and obvious differing characteristics with all signatures in the voter’s registration record may be rejected. To reject a signature, the county board must find beyond a reasonable doubt that the voter’s signature on the absentee envelope differs in multiple, significant, and obvious respects from all signatures in the voter’s registration record, and that the differences cannot be reasonably explained.

7. Reporting Requirements

   The State Board will closely monitor the pilot program and will compile and analyze the results upon completion of the pilot.

   County boards should keep careful records during the pilot and be prepared to report to the State Board their findings. Certain information is statutorily required to be reported by the county boards, including:

   1. Whether the signature verification software was used for all returned mail-in absentee ballots.
   2. How many executed mail-in absentee ballots were counted by the county board of elections in the 2024 primary.
   3. How many executed mail-in absentee ballots were flagged by the signature verification software.⁹

   The State Board will also survey the counties for certain additional information about the pilot, including:

   1. Any research indicating signatures identified in Tier 1 review as not matching were a match and any available information about why the mismatch may have occurred.
   2. Approximate staff time and county board time spent on the pilot.
   3. Suggestions or changes for how to implement signature verification statewide for absentee ballots.
   4. Suggestions on designing a process for how a voter can cure a deficiency related to signature verification of absentee ballots in the future.
   5. Any other feedback the county board would like to share.

³ Session Law 2023-140 provides the requirement to conduct a pilot program:

Section 48(a) The State Board of Elections shall select 10 counties in the State in which to conduct a pilot program during the primary held in 2024 for signature verification on executed mail-in absentee ballots. In selecting the 10 counties for the pilot, the State Board of Elections shall seek diversity of population size, regional location, and demographic composition. The pilot program shall consist of county boards of elections using signature verification software to check the signatures of voters noted on all executed mail-in absentee ballots received by the county boards of elections in the 2024 primary. The State Board of Elections shall select the signature verification software and ensure that the software is available for all 10 counties to use in the 2024 primary. The State Board shall assist the selected county boards of elections in implementing the signature verification software, including assisting the selected county boards of elections in any training needed on how the software is to be used for signature matching on executed mail-in absentee ballots.

⁴ G.S. § 163-31(d).

⁵ See page 3 [starting at “Board Member Access and Work in a County Board of Elections Office” if viewing the webpage version] of Office Operations During Pandemic: Numbered Memo 2020-17.

⁶ G.S. 163-82.10(a2):

The signature of the voter, either on the paper application or an electronically captured image of it, whether held by the State Board or a county board of elections, may be viewed by the public but may not be copied or traced except by election officials for election administration purposes. Any such copy or tracing is not a public record.

⁷ G.S. 163-82.10(a2).

⁸ G.S. § 163-274(16) makes it a Class 2 misdemeanor for any person who is not an elections official or who is not otherwise authorized by law to retain a voter’s signature from any form described in G.S. 163‑82.3 after submission of the form to the county board of elections or elections official.

⁹ Session Law 2023-140, Section 48(b).

Answers to Frequently Asked Questions

1. Will UOCAVA voters’ ballots be included in the pilot?

   Yes, if submitted by mail. Section 48(a) of Session Law 2023-140 requires that the signature verification software be used for “all executed mail-in absentee ballots received by the county boards of elections in the 2024 primary.”

2. What happens if the voter printed their name rather than signed in cursive on the absentee envelope?

   The signature on the absentee envelope must match at least one of the voter’s signatures on file with the county board. If the signature on the absentee envelope is printed, but the signature on file with the county board is in cursive, the board will still need to compare those signatures according to the criteria in this memo. In other words, the difference in the type of writing (cursive vs. print) is a dissimilarity in a broad characteristic that should be considered in determining whether there is a match. But that factor alone should not determine a mismatch. The board will still need to consider whether there are other dissimilarities. Also, keep in mind that some voters, particularly younger voters, may use a printed name as their signature. In this case, if the printed signature on the absentee envelope matches the printed signature on file with the county board, the signature on the absentee envelope should be approved.

3. What if the voter puts their initials instead of signing their full name?

   The use of initials alone is not considered a mismatch. As discussed in Section 6.3, the county board must consider as a possible explanation for a discrepancy that a voter printed their initials rather than the voter’s full name. This could include, for example, using a first initial instead of first name, or using initials entirely instead of the voter’s full name. If this is the case, the county board must go through the process outlined in this memo to compare the two.

4. What if the voter has a disability that prevents them from signing their name, such as a blind voter who submits their absentee ballot through the State Board’s online portal and uses a typed signature?

   The county board may not reject a signature due to a voter’s disability. As explained in Section 6.3 of this memo, the county board must consider any explanations for discrepancies between the signatures, including those caused by the voter’s disability. If the voter has attested under penalty of perjury that they have a disability that prevents them from signing, the typed signature should be approved.

5. What about if the voter makes their mark instead of signing, or what if the assistant writes “Disabled - cannot sign”?

   See the Appendix to this memo, starting on page 17 [next section if viewing the webpage version].

Appendix¹⁰

Note: Each of the examples below are designed to show what certain differing characteristics look like. This is not to suggest that in each example below, the signature should be rejected. A single differing characteristic is not enough to reject a signature. Instead, to reject a signature, the county board must find beyond a reasonable doubt that the voter’s signature on the absentee envelope differs in multiple, significant, and obvious respects from all signatures in the voter’s registration record, and that the differences cannot be reasonably explained.

¹⁰ This appendix was adapted from the Arizona Secretary of State’s Signature Verification Guide (PDF), Feb. 26, 2024.

Broad Characteristics

1. Type of Writing

   Next to spelling, the type of writing is the easiest characteristic to notice a difference in. Does the voter’s record have only cursive handwriting, but the absentee envelope has print? This is an immediate indicator for further research and review.

   

2. Apparent Speed of Writing

   A person writing their own signature will perform the act fairly quickly. This is because the person has likely signed their name thousands of times, so the gesture is automatic and harmonious, requiring little thought or concentration.

   If someone other than the voter took a long time to copy the voter’s signature, the copied signature will not have a free and natural look to it. Instead, you should see more deliberate marks. If the forger attempted to create the signature quickly, then it should have various characteristic differences.

   Keep in mind, however, that this situation may go in reverse. If the voter naturally has shaky or poor handwriting that is evident in the voter registration record signature, but the ballot’s signature is suddenly of high quality, that could indicate a forgery.

   Look to see whether the signature on the absentee envelope was made with the deliberateness as the signatures in the voter’s record. Keep in mind that a reasonable explanation for a shaky signature is the voter’s advanced age, decreased muscle strength, or the surface below the envelope.

   

3. Overall Spacing

   Writing a signature is a fixed and subconscious habit, so the signature’s spacing should be reasonably similar. Determine whether the signature on the absentee envelope has odd or unnatural spacing that cannot be reasonably explained.

   

4. Overall Size and Proportions

   The signatures’ size and proportions should also be reasonably similar. At your first impression, identify whether the signature on the absentee envelope is too large or small compared to the signatures in the voter’s record. This comparison may be difficult to perform by looking only at one voter signature. You may need to conduct further research or review additional signatures.

   The first example below has odd proportions because the letter’s height compared to the name’s length is very different than the genuine signature. The remaining two examples have unreasonably different sizes.

   

5. Slant of Writing

   Differences in a signature’s slant may also raise questions about a match. The first slant to be aware of is the signature’s position relative to the signature line. People tend to hold the pen and paper the same way each time they write, which causes their writing to slant in the same direction each time. You may also find that individual letters in the signature slant in the opposite direction. This type of deviation will usually accompany a difference in the signature’s overall spacing. See the third example below. Look to see whether the entire signature slants or leans in a different direction than the signatures in the voter’s record. A writer’s slant is one of the most consistent parts of their signature.

   

6. Spelling

   If the name is misspelled, you should seriously question the signature, unless there is some reasonable explanation — for example, it looks like the name is misspelled when, in fact, perhaps an atypical writing tool like a stylus was used and it did not create letters with the clarity that is typical in a voter’s signature. Bear in mind that a voter may use a common nickname or initials (for instance, a voter may sign as “Bobby” instead of “Robert”) so long as the characteristics of the signature remain the same.

   

Local Characteristics

1. Internal Spacing

   As mentioned before, the spacing and the relationship between successive letters should be reasonably similar. In the examples below, you will notice that the “R” in Ronald is much closer in the questioned signature than in the genuine one, and the questioned “Jimmy” has a great deal of space in between certain letters.

   

2. Size or Proportions of a Letter or Letter Combination

   Letter sizes and proportions should be reasonably similar. Review whether letters are the same size and whether letter height, when compared to the name’s length, leads to suspicious proportions.

   Below, the first questioned signature has unreasonable proportion in “Madison.” The remaining two signatures have noticeably different sizes in certain letters.

   

3. Curves, Loops, and Cross-Points

   Like size, these characteristics may be difficult to identify if you are comparing the signature on the absentee envelope to only one signature in the voter’s record. Some writers tend to have very loopy signatures while others have sharp, angular writing. Characteristics like loops and curves tend to be consistent across a person’s handwriting, but keep in mind that cross-points can be reasonably impacted by simple factors like the type of pen the person used, which may be a reasonable explanation for such differences.

   Find whether there are any noticeably different marks like in the examples below.

   

4. The Presence or Absence of Pen Lifts

   If someone is not familiar with a signature, they may have written in pieces or chunks. When this occurs, they will leave connection or hesitation marks that will not appear in the voter registration record signatures.

   Look to see whether there are any strange connection points or hesitation marks like in the examples below.

   

5. Beginning and Ending Strokes

   A genuine signature becomes automatic over time. This automatic nature leads to what appears to be “flying starts and finishes,” where the signature’s start and end points seem to vanish off the paper. Genuine writers tend to begin writing their signature before the pen even hits the page. A reason to question a signature is if there are larger ink dots or marks at the beginning or end of a signature.

   

Electronic Signatures

When reviewing signatures in the voter’s file, it is very likely that you will encounter some signatures that were created and captured electronically. DMV offices use an electronic signature pad to record signatures. In addition, voters who request an absentee ballot online sign electronically using a mouse or a finger on a touchscreen. These signatures are included in the voter’s record and are used as references when verifying their signature on the absentee envelope. Electronic signatures create some unique circumstances that you should consider when verifying a ballot affidavit signature.

When comparing an electronic signature to a handwritten signature, you should continue to consider the factors listed on the previous pages.

• This means you should begin your analysis by looking at each signature’s broad characteristics and if those characteristics are not clearly consistent, you should continue your analysis by examining the local characteristics.
• Keep in mind that the local characteristics of an electronic signature may be difficult to determine. Since the technology for electronic signatures is not as precise as pen and paper, it may be difficult, for example, to spot the presence or absence of pen lifts or beginning and ending strokes as space may be limited. Regardless, you should still consider all the factors described in the previous pages of this memo when comparing these signatures and make a decision based on the totality of what you find.

If, after going through your analysis, you find a combination of differences between the signature on the ballot affidavit envelope and the signatures in the voter registration record, ask whether the differences can be reasonably explained.

• You should consider that electronic signatures in particular may not be as precise as their handwritten counterparts and may even appear “blurry” or “messy” in comparison. It is possible that this may reasonably explain the difference between a handwritten and an electronic signature.
• Remember: You may need to look through the voter’s entire signature history to determine if the current signature on the absentee envelope was written by the voter. If you find that the electronic signature found in the voter’s history is difficult to read or match, it is possible there are other signatures on file that may be easier to read and distinguish. Before declining to accept a voter’s signature on the ballot envelope, review these other signatures to determine if the inconsistency is with the ballot envelope signature or with the electronic signature in the voter registration record.

1. “Messy” or “Blurry” Electronic Signatures

   Because the technology for capturing electronic signatures is not always as precise as a pen and paper signature, an electronic signature may appear “messy” or “blurry” in comparison. However, even a “messy” or “blurry” signature should be compared using the two-step process described above.

   In the first example below, the electronic signature found in the voter registration record looks vague and imprecise compared to the handwritten signature found on the absentee envelope. However, the broad characteristics appear to be substantially similar. The type, speed, spacing, size, and position of each signature appear to be the same and any minor disparities can be explained by the fact that one signature was created using an electronic pad and the other was created using pen and paper.

   In the second example, many of the broad characteristics are again substantially similar, although the electronic signature is not as precise as the handwritten signature. Regardless, these signatures can still be considered a match because the broad characteristics are substantially similar. If you decide an electronic signature is too “messy” or “blurry” compared to a handwritten signature to fairly compare, you should always look through the voter’s signature history to determine if there is a clearer signature on file.

   

2. Electronic Signatures That Have Been Cut Off

   In some instances, a person signing an electronic signature pad may have some of their signature cut off. This is likely because the voter’s pen stroke went outside the area that the electronic signature pad could capture. You should still compare the full electronic signature to the handwritten signature using the two-step process outlined in this memo. If you cannot verify the signatures using the two-step process, remember there may be more signatures in the voter’s signature history that you can use to compare.

   

Special Circumstances

1. Voters Who Are Unable to Sign or Make Their Mark Due to Disability

   Absentee envelopes contain a line for the voter to sign and a line for the voter assistant, if any, to sign. A voter assistant signature is required if the voter received assistance completing the envelope, marking the ballot, or mailing or returning their ballot. A voter assistant signature is also required if the voter is physically unable to sign or make their mark due to disability. In this case, the person assisting with the ballot should write in the voter’s signature line, “Disabled - cannot sign.”¹¹ If this is the case, no signature comparison will take place, because there is no voter signature to compare, and this will be noted accordingly in the county board’s spreadsheet.

2. Ballots With a Mark

   A voter who is unable to sign their name may instead make their mark on the signature line. A mark is an “X,” like in the example below, or some other sign or marking made in lieu of a signature. If a ballot contains a mark, the voter’s mark must be compared to the voter’s signature or mark on file for the voter.¹²

   

3. Signatures From Voters in Group Residential Facilities

   Pay close attention to pen strokes found on absentee envelopes from voters living in group residential facilities. The signatures of these voters are at a higher risk of having changed or deteriorated over time and may look less and less like the comparison signature found in the voter registration record. With this risk in mind, the following precautions should be taken when reviewing signatures from these voters.

   • Look for a pattern of deterioration in the voter’s signature history. You may do this for any signature that you review, but for signatures from voters in group residential facilities, taking this extra step can be even more beneficial. If the signatures you review in the voter’s file reveal a pattern of deterioration, then this fact may reasonably explain the difference between the ballot’s signature and the signatures found in the voter registration record.
   • Be mindful of the voter’s situation when reviewing signatures from group residential facility voters. Remember that if, after going through normal signature analysis, the differences between two signatures can be reasonably explained, you should accept a voter’s signature as valid.

¹¹ See Absentee Ballot Signature Verification Pilot Program: Numbered Memo 2022-11, explaining how disabled voters must be able to receive assistance to cast an absentee ballot.

¹² The law providing for the signature verification pilot program requires the county boards to check all signatures on absentee ballots against the voter’s records. See Session Law 2023-140, sec. 48. Accordingly, during the pilot program, if the voter makes their mark on the absentee envelope but the voter’s record contains only the voter’s signature, the signature will likely be found to mismatch. Other states, such as Arizona, account for this situation by requiring that an assistant sign the absentee envelope instead of verifying the voter’s mark when the voter is unable to sign due to disability. See Arizona Secretary of State’s Signature Verification Guide (PDF), Feb. 26, 2024, at 15. This requirement also avoids the difficulty of trying to compare a commonplace mark such as an “X” between documents. Such an accommodation would be appropriate for the North Carolina General Assembly to consider when assessing the results of this pilot program.

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