N.C. Gen. Stat. » Chapter 10B
NC General Statutes

N.C. Gen. Stat. § 10B-99 (2026)

Presumption of regularity

✓ current as of July 2026
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(a) In the absence of evidence of fraud on the part of the notary, or evidence of a knowing and deliberate violation of this Article by the notary, the courts shall grant a presumption of regularity to notarial acts so that those acts may be upheld, provided there has been substantial compliance with the law. Nothing in this Chapter modifies or repeals the common law doctrine of substantial compliance in effect on November 30, 2005.

(b) A notarial act shall be deemed valid if it complies with the law as it existed on or before December 1, 2005. This section applies to notarial acts whenever performed. (2006-59, s. 24; 2006-199, s. 4; 2013-204, s. 1.10.)

 

Article 2.

Electronic Notary Act.

Part 1. General Provisions.
Notes of Decisions
Cited in 8 cases (4 in the last 5 years), 2014–2022 · leading case: Sfreddo v. Hicks, 831 S.E.2d 353 (N.C. Ct. App. 2019).
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Sfreddo v. Hicks, 831 S.E.2d 353 (N.C. Ct. App. 2019). · cites it 6× “Presumption of Regularity of Notarial Acts We first note the cases and statutes governing notarial acts 3 and the presumption of regularity of notarial acts: In the absence of evidence of fraud on the part of the notary, or evidence of a knowing and deliberate violation, we…”
In re: Ivey, 810 S.E.2d 740 (N.C. Ct. App. 2018). · cites it 4× “" N.C. Gen. Stat. § 10B-99(a) (2015). Specifically, the Iveys contend that the trial court's finding that Mother did not receive a copy of the Consent at the time it was signed despite the notary's certification that "to the best of [his] knowledge and belief .”
In Re Adoption of \Baby Boy\"", 757 S.E.2d 343 (N.C. Ct. App. 2014). · cites it 4× “N.C. Gen. Stat. § 10B-99 (2013). This presumption of regularity allows notarial acts to *500 be upheld, “provided there has been substantial compliance with the law.”
In re C.N.R. (N.C. 2021). · cites it 18× “N.C.G.S. § 10B-99 provides that, [i]n the absence of evidence of fraud on the part of the notary, or evidence of a knowing and deliberate violation of this Article by the notary, the courts shall grant a presumption of regularity to notarial acts so that those acts may be…”
In re C.N.R. (N.C. 2021). · cites it 18× “N.C.G.S. § 10B-99 provides that, [i]n the absence of evidence of fraud on the part of the notary, or evidence of a knowing and deliberate violation of this Article by the notary, the courts shall grant a presumption of regularity to notarial acts so that those acts may be…”
Bruton v. First Citizens Bank & Trust Co. (Bankr. M.D.N.C. 2021). · cites it 14× “N.C. Gen. Stat. § 10B-99 (2021). The doctrine of substantial compliance is based on the rationale that “notaries do not have to be perfect or exacting in their official actions, if they are predominantly complete and correct in what they do.”
Surratt v. Brown, 2016 NCBC 27 (N.C. Bus. Ct. 2016). · cites it 2× “See N.C. Gen. Stat. § 10B-99(a) (2015). factual disputes as to the existence of the second agreement that preclude it from granting summary judgment as to any portion of the breach-of-contract claim.”
Cynthia Butler v. First Citizens Bank & Trust Co. (4th Cir. 2022). “1921); N.C. Gen. Stat. § 10B-99(a) (2021). Accordingly, we affirm the district court’s order.”
— N.C. Gen. Stat. § 10B-99(a) — 5 cases
In re: Ivey, 810 S.E.2d 740 (N.C. Ct. App. 2018). “" N.C. Gen. Stat. § 10B-99(a) (2015). Specifically, the Iveys contend that the trial court's finding that Mother did not receive a copy of the Consent at the time it was signed despite the notary's certification that "to the best of [his] knowledge and belief .”
In re C.N.R. (N.C. 2021). “N.C.G.S. § 10B-99 provides that, [i]n the absence of evidence of fraud on the part of the notary, or evidence of a knowing and deliberate violation of this Article by the notary, the courts shall grant a presumption of regularity to notarial acts so that those acts may be…”
In re C.N.R. (N.C. 2021). “N.C.G.S. § 10B-99 provides that, [i]n the absence of evidence of fraud on the part of the notary, or evidence of a knowing and deliberate violation of this Article by the notary, the courts shall grant a presumption of regularity to notarial acts so that those acts may be…”
Surratt v. Brown, 2016 NCBC 27 (N.C. Bus. Ct. 2016). “See N.C. Gen. Stat. § 10B-99(a) (2015). factual disputes as to the existence of the second agreement that preclude it from granting summary judgment as to any portion of the breach-of-contract claim.”
Cynthia Butler v. First Citizens Bank & Trust Co. (4th Cir. 2022). “1921); N.C. Gen. Stat. § 10B-99(a) (2021). Accordingly, we affirm the district court’s order.”
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