Page "Civil law notary" Paragraph 10

Save for Louisiana, Puerto Rico, and Quebec, a civil-law notary should not be confused with a notary public in the United States and Canada, who has none of the legal powers notaries enjoy at civil law.

Rather, notaries public only have the power to administer oaths, take affidavits, declarations or depositions from witnesses, acknowledge and attest signatures, and certify copies, usually in conjunction with some legal process.

In Louisiana, Puerto Rico, and Quebec, private law is traditionally based on the French and Spanish civil codes, giving notaries greater legal powers, including the right to prepare wills, conveyances and generally all contracts and instruments in writing.

For this reason, immigrants from civil-law countries where civil-law notaries exist, particularly those from Latin America, are often confused by the office of notary public and have been defrauded by dishonest notaries misrepresenting themselves as having legal powers.

Thus, in some states there have been ongoing efforts to prohibit notaries public from listing themselves as notario público.

Such a law has existed for more than fifteen years in California.

Similar laws now exist in Texas, Illinois, Tennessee, Georgia, and Florida.