Signature vs. seal

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The Japanese may be forgetting how to write kanji ("Japanese survey on forgetting how to write kanji"), but, so far as their signatures are concerned, perhaps they don't really need to write them anyway, since they still rely heavily on seals for affixing their John Hancock to documents.  When I lived in Japan (around 1995), even I had to purchase a seal, or I wouldn't have been able to get properly registered as a resident alien.

Once, in connection with some artifacts from China, I asked the Director of the archeological institute who was going to give them to me if he could prepare a certificate stating that I had the right to submit them to C14 and other types of analysis.  He said he'd be happy to provide such a certificate, but that his institute had undergone a reorganization and renaming, and he was waiting for a new seal.  So I waited patiently for the certificate, but the seal just kept getting delayed.  Finally, when it came to the point that I desperately needed the certificate right away, I told the Director just to send it to me with his signature affixed.  He laughed and said to me that such a certificate was worthless, since his signature meant nothing, whereas the seal meant everything.  But I told him that, in the West, his signature meant everything and the seal meant nothing.  He finally yielded to my entreaties and sent the certificate with his signature, experiencing a shock upon learning that his signature was more important to me than the seal of his institute.

I've had this sort of thing happen to me many times in China and Japan.  And something similar happened recently to an American expat in Taiwan.  I sent him a check as a contribution to a cause we both believe in.  He wrote back:

I deposited it yesterday, which turned into an ordeal when the people at the bank said that my signature wasn't right.

I noted, "It's my signature. How can it not be right?"

"It needs to look more like a printed version so people can read it," the cashier replied.

"But then it could be anyone who signed it. This is supposed to be *my* signature, and that's what it looks like."

They were afraid the bank in America would reject the check because of the signature. So they were about to use white-out to remove my signature so I could do it again — at which point I reacted with alarm and told them that if they tried to white out the authorization section of a check it probably would be rejected — and that then it would be their fault.

On and on like that for nearly an *hour*.

It's times like that I miss America.

On the other hand, I've also had banks here be especially accommodating to me. For example, during my first year in Taiwan I worked for an organization that issued paychecks, which is uncommon relative to direct deposit or even payment in cash. But this tradition-bound organization insisted upon issuing paychecks to me using my Mandarin* name (in Hanzi, of course). The first time I went to deposit a check in my banking account I had *no* official identification bearing that name, which has only a vague resemblance to the pronunciation of my Western family name.

"Really, it's me," I would say, trying my best to look innocent.

And they believed me and deposited the check.

Of course, I should have added my Mandarin name to my account then and there. But I forgot. So I had to go through the same thing the following month — fortunately with the same result.

So although my signature has been regarded as improper, despite documentation and, well, logic, I have also had the good fortune to be trusted to be the same person as someone who was identified only by a Chinese name.

Of course, what my friend experienced at his bank in Taiwan (not writing his own signature properly) is different from the problem of seal vs. signature that I described above, yet it also reveals what seems to be an emphasis on form over function in sinographic cultures.

My recollection from the years I lived in Taiwan (1970-72) is that seals were still very important then, and I had to use mine to take care of a lot of official business.  Whether that was a holdover from the days of the Japanese empire or whether seals were also very important in Republican China when it was on the mainland, I do not know.


  1. Jim said,

    October 1, 2012 @ 1:55 pm

    "…yet it also reveals what seems to be an emphasis on form over function in sinographic cultures."

    It doesn't have anything to do with sinographic cultures, it has to do with the functional requirements of bureaucratic systems such as banking, which can only be stated in terms of form. Individuals in such a system don't have much latitude to use their own judgement to decide matters of function; that defeats the purpose of standardizing and regularizing the procedures that constitute the system.

    Privileging a seal over a signature in this or that system, or requiring a proper Chinese name, or at least Chinese-looking name, when a person is in China is just part of getting people to fit into the system. This is the same kind that bedevils Somalis in the US, where they continually have to show birth certificates and documents like that, which don't exist and are unavaliable in Somalia.

  2. MD said,

    October 1, 2012 @ 2:01 pm

    What Jim said. Seals are a requirement everywhere in the former Soviet Union. I had a visitor once who needed a letter back to his home institution confirming his visit, and it was more than a little tricky, because we did not have anything that would be recognized as a proper "seal" in Ukraine; poor secretaries were at a loss at how to help someone from a country where signatures are useless. And, of course, Ukrainian is not a sinographic system at all, it's just how the bureaucracy works.

  3. J.W. Brewer said,

    October 1, 2012 @ 2:13 pm

    Seals used to be very important indeed in the (non-sinographic) Anglo-American legal system, but their significance has fairly radically declined over the last two centuries. See, e.g., (Note however that the "L.S." annotation that is a fossil of a genuine seal can still be seen on a few types of documents U.S. lawyers produce today although it is almost certainly vestigial – but who wants to be the one to experiment with the consequences of leaving it out?) On other hand, for certain sorts of official documents like a college transcript or birth certificate, people still want a seal. Those contexts, however, tend to be different from an East Asian "chop" that substitutes for a given random individual's signature – rather they are most commonly used on documents where the individual's signature as such is of no great moment because what matters is the ability of the individual (who might be a quite low level clerk) to certify the accuracy and authority of the document on behalf of his/her institutional employer. I have let the license lapse, but not too many years ago I was a notary public, in which capacity I had in my desk drawer a seal which could make documents I notarized seem more fancy and offical-like.

    For banking purposes in the U.S. it is quite common for businesses and other collective institutions to have rubber stamps bearing the name of the entity which are used to endorse the backs of checks for deposit in lieu of a signature by a particular individual authorized to act on behalf of the entity.

  4. Helgi Briem said,

    October 1, 2012 @ 2:28 pm

    Whilst here in Iceland, we skip the problem entirely by not using checks at all. In fact, many people under 30 don't even know what a check is.

    Practically all commerce is digital these days and it is often said, not quite jokingly, that the only people who use cash are drug dealers, old age pensioners and tourists.

  5. Fred Thrung said,

    October 1, 2012 @ 2:42 pm

    I came across this seal ("chop") nonsense when I was running companies in S E Asia in the 70's. I finally had a seal made up which read something like Zyrnowski (Poland) plc. Worked most of the time.

  6. Bruce Rusk said,

    October 1, 2012 @ 2:56 pm

    Once upon a time people (at least members of some elites) in East Asia did use signatures: Chinese huaya / Japanese kaō (華押). These are ornate, highly stylized signatures that were used in situations in which, in other times, seals would be used. The practice started in the Tang period, in China, and lasted until the 19th c. in Japan. But they have fallen out of favor in modern times, and seem to have no legal standing today.

  7. Catanea said,

    October 1, 2012 @ 3:04 pm

    Some actual Spanish person may support this anecdotal evidence: I was told earlier in my Spanish residence that many clerkly jobs required a seal, and that those people who didn't happen to have a seal, were told to just use one of their shirt buttons. (This was the sort of seal that had to be imprinted in wax).

  8. Theodore said,

    October 1, 2012 @ 3:22 pm

    Seals are still in wide use in the U.S. in architecture and engineering but their usage has become increasingly vestigial in the 17 years since I've had one.

    Individuals typically obtain a seal (usually a rubber stamp, occasionally an embosser) upon licensure in a particular state and affix the seal (with a signature!) to documents submitted to local construction permitting authorities, etc.

    Of course since many documents are now created and transmitted electronically, some jurisdictions will allow the seal to be electronically generated in the document and the signature inserted as a scanned image.

  9. JMU said,

    October 1, 2012 @ 6:14 pm

    It is sometimes said that seals were traditionally used in Japan to prevent forgery, but I recall reading that this was not the primary reason. The Tokugawa bakufu did not make seals mandatory for ordinary folk until the latter half of the 17th century. The important thing was that seals had to be registered with the authorities to be proof of identification on documents.
    My wife had an English teacher in Kobe long ago who always signed for things at the post office. No matter how many times he went there, the regular clerk always asked him first to use a seal. He always politely said he had none, whereupon the clerk then—and only then—let him sign. This went on for years. Eventually, he went to a shop and had a large square seal carved with the characters 馬鹿 _baka_ ‘dope’. The next time he went to the post office, the old ritual ensued. “Don’t you have a seal?” the clerk asked. The teacher quickly produced his new chop, loudly stamped a large and bold 馬鹿 in the required spot, and thrust the paper before the clerk’s eyes. The stunned clerk, getting the message but rather at a loss for a snappy face-saving riposte, stammered out, “A! A! Umashika-san desu ka” (Omigosh! That’s Mr. Horse-and-deer, of course!) Saved by multivalent kanji readings!

  10. B.Ma said,

    October 1, 2012 @ 6:40 pm

    Well, in Hong Kong I've only ever used a seal for traditional / cultural purposes (i.e. for fun). Everything legal / relating to the government requires a signature. So nothing to do with "sinographic cultures" and everything to do with how officialdom works.

  11. maidhc said,

    October 1, 2012 @ 11:59 pm

    Something I've observed is that in some parts of the Middle East people use a hand-written signature, but it's not a way to write your name, it's just a design that you select. Sort of a hand-written seal. I haven't made a study of it so I'm not sure exactly what countries this is common in.

  12. Peter said,

    October 2, 2012 @ 12:47 am

    I once had to do a medical examination in the US for a job in China. I forwarded the relevant papers to my future employers, but they responded, "We can't accept these; they don't have a seal." I went back to the Clinic and had one of the receptionists stamp it with a mailing stamp with the logo. Problem solved.

  13. LDavidH said,

    October 2, 2012 @ 7:56 am

    Just a question from an ESL speaker in the UK: when you say "seal", do you always mean "rubber stamp" (or similar made out of some other material) that makes an ink imprint, or is there another meaning to it as well?

  14. M (was L) said,

    October 2, 2012 @ 9:49 am

    In American usage, and I think in UK usage, it rarely means a rubber stamp – though in this context it would probably include that.

    More likely, it means an embossed impression of a seal, applied with a hand-operated clamp-like device – examples here:

    Certain documents require a third-party notary embossing to assure the identity of the person signing the document. The process is silly, really – an extra errand for some guy in a stationery shop to make a cursory glance at my driver's license, jot down the number, crimp the paper, and collect a small monetary charge for the service. He doesn't make a living doing this, but it probably buys him lunch now and again.

    It could also, mostly in the past, mean an impression pressed into wax. This is very rare in the US, but I think has some special uses in the UK.

  15. Dan Lufkin said,

    October 2, 2012 @ 9:55 am

    As a translator I often prepare translations of documents for submission to foreign embassies. Until about five years ago there was no such thing as a legally "certified" translation in the USA and the embassies often rejected the translations out of hand. Finally I went to an office supply store and ordered an embossing seal with "CERTIFIED TRANSLATION". It worked like a charm, even with the embassy of everyone's second homeland, previously the most adamant. (The American Translators Assn. now has a certification program with examinations and a digital seal that works well.)

  16. M (was L) said,

    October 2, 2012 @ 10:33 am

    @maidhc –

    > Something I've observed is that in some parts of the Middle East
    > people use a hand-written signature, but it's not a way to write
    > your name, it's just a design that you select. Sort of a hand-written
    > seal. I haven't made a study of it so I'm not sure exactly what
    > countries this is common in.

    It might be a calligraphic cartouche of their name, there is an Arabic/Islamic tradition involved.

    It's common in the US, and at least at one time in diplomatic circles, to initial pages or items on a form to indicate awareness, acceptance/choice of option, corrections, etc – all subject to a final signature agreeing to the document as a whole (without which the initials alone agree to nothing). Most people who do this fairly often, develop a sort of ligature/logo of their initials; eg, former US VP & politico Hubert Horatio Humphrey used four vertical lines and a horizontal through all of them to initial HHH. Sort of like a tally mark "5" almost.

  17. Mr Punch said,

    October 2, 2012 @ 11:42 am

    Has anyone, in this discussion of kanji and seals, mentioned the fax machine? I've heard that a technology (originally American, I believe) that had existed for decades was perfected and popularized in Japan because executives there wanted to be able to show their facility with script, a traditional marker of social status.

  18. Peter said,

    October 2, 2012 @ 11:47 am

    @DanLufkin That's pretty excellent.

  19. hanmeng said,

    October 2, 2012 @ 1:13 pm

    When I last went to a notary in the U.S. a few weeks ago, she used one to notarize my signature. She also required me to leave my thumbprint in her book. How barbaric and demeaning!

  20. Nathan said,

    October 2, 2012 @ 1:34 pm

    When I was living in Kinmen Island, Taiwan, last year, I opened a bank account for direct deposit of my wages. The bank officer asked if I had a chop; if I didn't have one, I could use my signature to open the account. As it turned out, I had already had a chop made for when I was registering for a bus card or something. So I proudly used my stamp. Problem came a few months later, when I wanted to withdraw money and the ATM wasn't working. They asked to see my chop, and I'd forgotten to bring it. At this point, my signature wouldn't do, because when I opened the account I used the chop as my means of identification. This was bad for me in two ways: first, it was inconvenient to remember to bring the chop with me. Second, anyone who saw the stamp could go to the print shop and get a chop engraved exactly like it for about $2 US.

  21. E said,

    October 2, 2012 @ 3:59 pm

    On the flip side of Nathan's observation, but not as amusing as JMU's:

    As recently as ten years ago, registering for a bank account before receiving or registering a seal meant that you would have to place your signature in a tiny round space (designed for seals) on the account creation form. Every time after that, you would have to sign your name in the tiny round space on transaction forms (deposits, withdrawals, direct payments, foreign currency purchases). If the regular teller or manager was not there, the process would take about twice as long as they confirmed that, yes, that was the authorized signature and it was sufficient without a seal.

    I imagine that this is only possible if the individual involved is not Japanese.

  22. Kellen said,

    October 3, 2012 @ 9:54 am

    I currently live in Taiwan and, though not forced, got a seal as soon as I arrived. While a number of expats get along fine without, I knew it would make things like buying a vehicle or renting an apartment much easier. In some cases if you deal with businesses or agents who aren't accustomed to foreigners, lacking a seal means you end up putting your thumb print in red on whatever the document in question is. So far, having the seal and thus making everything go a little smoother has been completely worth the cost of getting it carved in the first place.

  23. Kellen said,

    October 3, 2012 @ 9:56 am

    I forgot to mention, when I opened my bank account and gave them my initial signature (together with the seal), they said with stern looks on their faces "Make sure you do it just like this every time from now on," relating pretty well to your friend doing his own signature incorrectly.

  24. Christopher Browne said,

    October 3, 2012 @ 10:32 am

    I have been collecting seals over the years as a result of becoming an officer of a succession of (not very busy!) Canadian corporations.

    There only seem to be a couple of documents where it is legally necessary to apply the seal, basically at the time of incorporation, after which the seal remains something of a curiosity. It appears that the seal is no longer required for "business corporations", but is, for unclear reasons, still mandatory for not-for-profit corporations.

  25. mictter said,

    October 3, 2012 @ 11:27 am

    Never heard of it (I'm Spanish, and have lived most of my life here). With regards to seals and signatures, Spain is mostly like any other Western country: individuals do not usually have their own seals, but use quite ornate signatures. Rubber stamps are everywhere in the bureaucracy, but we are not an exception in this either.
    Transactions are made easier by having government-issued IDs, that's all.

  26. Henning Makholm said,

    October 3, 2012 @ 12:03 pm

    What does this "get a seal" operation entail? Do you need to pay a sealmaker to invent a seal for you, with sufficient entropy built into it to identify you? And then you have to trust him not to keep a copy of it that he can use to impersonate you later?

  27. Martin Ewing said,

    October 3, 2012 @ 12:13 pm

    Years ago, I was living in Australia, but I needed to have a US real estate document "notarized". The way to do this was to go to the US Embassy in Sydney, where I showed my passport or other ID. Then they proceeded to wrap my document in a folder with a large red ribbon and wax (?) seal. Quite a nice bit of art! I don't know if the US bank was particularly impressed.

    This is how the diplomatic crowd operated for a long time and perhaps it continues to do so.

  28. R Hayes said,

    October 3, 2012 @ 12:27 pm

  29. Chromatix said,

    October 3, 2012 @ 12:38 pm

    In the 17th and 18th centuries, the illiteracy rate was still pretty high in Britain, which was a minor problem when a ship's crew needed to be signed on for the Royal Navy. Excluding every man who couldn't write his own name would have undermanned the Navy very badly. So the practice was that an illiterate could "make his mark", usually a crude X, on the document required, after a literate officer had written his name on the list and read the articles to him.

    At the same time, the aristocracy were still using wax seals on envelopes, if only as a way to ensure that a letter was both authenticated and had not been snooped at in transit. Needless to say, methods of lifting and reapplying genuine seals (eg. using a hot knife) were developed to get around this. Often the sealing implement would be a "signet ring", worn at all times by the gentleman concerned to ensure it was not lost or stolen.

    I think rubber stamps are a relatively recent innovation in the West, and are chiefly used for high-volume authentication. Indeed, "to rubber-stamp" is perjoratively used to mean passing a motion with minimal deliberation. In the postal service, they are still often used to simultaneously "cancel" a postage stamp (the means of payment) and authenticate the package as having been paid for; the mark includes the place and date, which is potentially useful for downstream authentication purposes.

  30. tm said,

    October 3, 2012 @ 1:37 pm

    I got to learn about the international convention that governs how countries treat each other's public documents thanks to a lemon.
    A few years back, my brother-in-law in Japan had a lemon of a Dodge Durango that spent more time in the shop than it did on the road. A Carfax report we ran on the VIN showed that it had once been a rental and that the odometer had been rolled back.
    Unfortunately, official recourse via the local authorities here (the Durango had been registered in California where I lived) generally entailed the following conversation:
    Me: So, my brother-in-law has this Durango and the odometer has been rolled back and he needs some sort of official document stating this.
    DMV: Oh dear, unfortunately that happens a lot. Where is the vehicle now?
    Me: Japan
    DMV: Um, I don't think we can help you, sorry.

    What I ended up doing was notarizing a statement affixed to the Carfax report stating that it represents the accurate history of the car according to the appropriate state authorities (a nice gent at the Bureau of Automotive Repair let me know that Carfax uses their data for these reports). After it was notarized, it was off to the local CA Secretary of State office to have a very fancy page with an equally fancy embossed seal attached to the front of what I submitted. Under the Apostille convention, this made it a document that could be treated as notarized in any other country that was a party to it. At any rate, it was a very fancy page and embossed seal proclaiming that my signature was all good.

    This was shipped off to Japan, where my brother-in-law's lawyer presented it to the dealership that sold him the car. They quickly settled with him upon seeing the impressive looking apostille.

  31. J Booth said,

    October 3, 2012 @ 1:40 pm

    While seconded to the UN in the Balkans a decade ago, I had similar issues regarding "seals". The problem was solved when my wife sent me one of her nieces Disney World rubber stamps. After a few careful cuts with an “X-acto” knife to make it look official and old, I never had a problem.

    My only concern is that in hundred years from now, when future historians are examining these official documents what will they think when find a Disney Land seal on an official UN document.

  32. Dan Hill said,

    October 3, 2012 @ 1:55 pm

    @Martin Ewing – as of mid-2011 it certainly still worked like that because I had exactly the same experience being in Australia while closing on a real estate sale in the US. But what do you have against the pretty red ribbon? You could of course have the document notarized at the US Consulate in Sydney. In theory. Between 12 and 12:15 pm on the second Tuesday in any month ending in the letter y.

    There's been a number of mentions of Hong Kong. A mix of British law and Chinese culture, so generally signatures are acceptable, but there are plenty of occasions, especially in a commercial setting, of being asked to affix the "company chop." Took me a while to figure out what a chop was.

  33. Johanne D said,

    October 3, 2012 @ 1:59 pm

    @ mictter:

    It was explained to me that this ornate signature was called the "firma y rúbrica" ("La RUBRICA es la línea o especie de dibujo que se realiza o no debajo o por encima de la firma") and that it was mandatory — a simple signature would not do. Don't know if that's true or if it's just a custom.

    Some of them can be very pretty.

  34. Victor Mair said,

    October 3, 2012 @ 6:47 pm

    The legal aspects of digital signatures will become complex.

  35. Jean-Paul said,

    October 3, 2012 @ 8:54 pm

    I am surprised that the long history and traditions of using wax seals has only gained cursory commentary here, particularly the European context.

    This appears to be where chops, signet rings, and the like have all evolved from.

  36. M (was L) said,

    October 4, 2012 @ 8:44 am

    @Victor Mair

    > The legal aspects of digital signatures will become complex

    Not to quibble, but I think they became complex some time ago, and they continue to get more and more involved.

    Seals and signatures have always been vulnerable to forgery and always will be, and it may simply be that we haven't yet found a tolerable balance in the digital realm. Forgery will never be 100% eliminated, but a satisfactory system controls it "well enough."

    Whatever one person can do with proper authority, a sufficiently skilled forger can mimic without proper authority, it's just a question of how much skill it takes, how much time it takes, and much it costs to commit the forgery. Make those barriers high enough, and you limit forgeries to few enough. Zero is always the goal, but there's an obvious arms race involved.

  37. Victor Mair said,

    October 4, 2012 @ 4:37 pm

    @M (was L)

    No, you did quibble.

  38. Alex said,

    October 4, 2012 @ 5:19 pm

    The UK is almost entirely signature based, but laws are still given the imprimatur of the Great Seal of the Realm:

  39. Nanani said,

    October 5, 2012 @ 12:30 am

    I've been in Japan for half a decade, and while most people and organisations have come to understand how signatures work, I've also had the "you have to sign it so people can read it" misunderstanding.
    It was only once though, and I blame on the clerk that day being particularly obtuse as further transactions in the exact same organisation have not had this requirement.

    For the record I do have a seal, but I use it only for opening new bank accounts and the like. Lesser forms I will insist on signing for, and it normally works fine.

    tl;dr: Japan is not irrevocably bound to seals.

  40. Narcís said,

    October 5, 2012 @ 3:09 am

    Some actual Spanish person may support this anecdotal evidence: I was told earlier in my Spanish residence that many clerkly jobs required a seal, and that those people who didn't happen to have a seal, were told to just use one of their shirt buttons. (This was the sort of seal that had to be imprinted in wax).

    I'm Spanish and I've never heard of anything remotely similar to this case. In fact, personal seals are really uncommon these days. I, for instance, know no one who has one.

    Which was more common years ago was firgerprinting documents, but nowadays this is very rare too, however still accepted as a signature.

  41. Rodger C said,

    October 5, 2012 @ 11:16 am

    I once had a problem with my signature being illegible on a check in a California supermarket. The clerk was a recent immigrant from Japan.

  42. SteveLaudig said,

    October 6, 2012 @ 1:10 am

    A story, true enough, I was a lawyer who represented criminals. Once a client came to me who had not been charged but had a question about what he/she was doing. He/she had purchased an 'official looking' stamp that said. "Paid in Full". When he/she got an unpaid bill in the mail he/she simply stamped it, in red, and mailed it back to the company. He/she asked me if she was committing a crime. I guess I wasn't a very clever lawyer as I responded that I didn't care to find out but that my advice was to quit doing it. I never heard back from him/her.

  43. Yosemite Semite said,

    October 6, 2012 @ 6:02 pm

    Many countries that are part of the Hispanic world use ornately hand-drawn designs sometimes incorporating the letters of the signer's name to confirm their identities on documents. My wife, who was born and grew up in Mexico and still conducts various kinds of institutional transactions there although she has lived outside the country for some thirty years now, recently had to make one of those transactions. She signed her name as is customary in Canada where she went to university and in the U. S., where she lives, with something that looks like letters in English. In many cases, of course, even though some initial letters may be recognizable in a signature here, it often fades off into illegibility. Hers, however, doesn't. When she was done, the official with whom she was dealing told her that she needed to affix her signature — one of those hand-drawn ornate designs with multiple flourishes, rather than spell out her name. The official finally accepted that that was her signature. Checking for images of firmas on ( turns up a number of examples, although mixed with signatures from other cultures.

  44. MadLogician said,

    October 8, 2012 @ 2:28 am

    A few of us in the UK set up a company to take over the freehold of our block of flats. I found that with the company documents came a metal company seal of the kind described by an earlier poster. Certain documents such as share certificates require both signatures of the company officers and the use of the seal.

  45. TheBearInBoulder said,

    October 10, 2012 @ 10:23 am

    I recently filled out some online paperwork for a pre-employment background check. As the final step it wanted me to 'sign' the document using my mouse.

    It wouldn't accept my signature. It wasn't 'dark enough' (by which I think they meant it was too simple – I have a short name and over the years it's devolved into just a few squiggles.)

    Unfortunately I've actually had to research this in the past (see squiggles) so I know that in the US what usually matters is the UCC and it just says a 'tangible mark' indicating assent. It says nothing about it being legible, being related in any way to your legal name, or even in the nominal authentication area. Merely hand-writing a check (but 'forgetting' to sign it) is enough.*

    In this case I did just make some squiggles and sent email to my contracting company telling them about the situation. But it's not hard to see this becoming a problem in the future if there's an unholy alliance between sites that refuse to accept some signatures and other sites that use image processing to decide whether the signature you just provided matches earlier signatures on file.

    * We often forget the bigger picture. In a business transaction (which is what the UCC – Uniform Commercial Code – addresses) there's only one of three possibilities. EIther you intended it (and any question is a moot point), you intended to defraud the other party (which is a crime in any case), or somebody forged your signature and it's a matter of nonrepudiation. In the last case most people will trust a matching signature on driver's license over a legible but inconsistent signature.

  46. Vladimir G. Ivanovic said,

    October 15, 2012 @ 12:00 am

    I once (early '70's) went to cash a $25,000 check from my stock brokerage company at the bank in New York City on which it was drawn, and I presented my passport for ID. They compared my signature on the back of the check (signed in front of them, of course) and the signature on the passport, and they did not match because my signature had deteriorated into a bunch of squiggles.

    So I resigned using the style on the passport, and off they went to process the check, only to come back with something like, "Insufficient Funds". My broker was White, Weld & Co. which had a stellar reputation, so something was clearly amiss.

    It turned out that the account on which the check was drawn was a "zero balance" account: at the end of the day White, Weld would deposit just enough to cover the checks which had been cashed.

    So, I walked out onto the big bad streets of New York City — with $25K in my pocket. I forget why I wanted the $25K, but I sure could use that money now…

  47. Leslie Turriff said,

    October 15, 2012 @ 7:52 pm

    Regarding online signatures and such, I never know whether to laugh or groan when signing my signature for a credit-card transaction on one of those electronic touchpads; the stylus has no traction, and the resolution is so poor that the signature seldom bears any resemblance to what it would look like on paper.

  48. BobW said,

    October 16, 2012 @ 10:33 am

    @Jean-Paul. That would be the emblem entry in Wikipedia and not the "semi-aquatic marine mammal" one, right?

  49. wgj said,

    November 28, 2012 @ 4:32 am

    This discussion is somewhat messy because "signature vs. seal" doesn't specify *whose* signature it is about. If it's one's signature vs. the seal of the organization to which one belongs, that's not so much "signature vs. seal" as it's "individual vs. collective", which is a complete different and much more prominent theme of the east-west divide.

    The real "signature vs. seal" contrast should be about a person's signature vs. his personal seal. On that I can offer the following observation about the situation in mainland China: Within the last two or three decades, signature has replaced seal.

    Back in the eighties, when I was a child, everyone had his personal seal (except us children, that is), and it was used everywhere. For example, you couldn't pick up a package for you from the post office (packages weren't delivered back then, and there was no express service) if you had forgot to bring your seal. Nowadays, practically nobody in their forties or younger has one, and the elderly who do haven't used them for years. Young people in their twenties probably aren't even aware of the past when their parents and grandparents stamped instead of signed.

    Since I left China as a teenager, before being old enough to need a personal seal (actually, I have quite a collection of my own seals, some bearing my name, and some I've carved myself, but none of them are of "official" nature, as they are all calligraphical seals), I can't pinpoint the exact time when the switch happened. It must have happened rather swiftly, as were other aspect of the westernization of mainland China.

  50. wgj said,

    November 28, 2012 @ 4:37 am

    PS: Though rarely practiced, the use of personal seal (if you have one) instead of signature is still legitimate in many if not most traditional institutions in mainland China, like the post office or the bank.

  51. SB said,

    March 11, 2013 @ 1:59 pm

    @Maidhc: "Something I've observed is that in some parts of the Middle East people use a hand-written signature, but it's not a way to write your name, it's just a design that you select. "

    Is it similar to a monogram or to what is called "seing" in French ? :

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