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Best Practices - Filing Description Continued

The last few Weekly Tips discussed what information should and should not appear in the Filing Description. As the TOI and Filing Type generate the submission requirements that appear under the State Required Supporting Documents tab applicable for the filing, each submission requirement should be satisfied in the Comment field of that submission requirement. It is not appropriate for the Comment field to reflect "See Filing Description" or for the information contained in the submission requirement to be duplicated in the Filing Description.

For filings that contain an application, an Application Use submission requirement will be generated when the Filing Type includes the term "application". Use the comment field of that submission requirement to include a statement of how the application will be used, such as paper, electronic, and/or telephonic as this information is required to satisfy a uniform standard requirement.  Further, if the application can be used electronically or telephonically, uniform standards also require a description of the procedures that will be used to verify the authenticity of the transaction. This information should also be included in the Application Use submission requirement comment field. If the company has a document that discusses the electronic and/or telephonic application procedure, it is appropriate to include the document in this space as well by uploading the attachment.  

Each submission requirement appearing under the State Required Supporting Documents tab includes a Description box that instructs how the filer can satisfy that applicable submission requirement. Best practice is to complete the Comment field by following the guidance provided in each Description box. Doing so will create review efficiency and eliminate compliance issues.  

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