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Cross-Media Electronic Reporting Rule

Lesson 7: Key Decision 2 - Defining the Copy of Record (COR)

What the system defines as the COR determines:

  • How the COR is Shown to be "True and Correct"
    • The closer the COR is to the file received, the easier a "true and correct" showing may be, since there will be few or no transformations of that file to account for.
    • For CORs that do not have an associated hash value, a "true and correct" showing will depend heavily on how their access is secured, controlled, and logged.
    • If CORs can incorporate changes to their content—for example, to accommodate submitter corrections—then a "true and correct" showing will depend heavily on a chain of custody that documents all such changes and their circumstances.
  • How Opportunity to Review is Provided
    • The COR's format will determine what processing is needed for a "human-readable" version.
    • The medium in which the COR is maintained (e.g. electronic or paper) will affect how it can be provided for review.

For example, consider the following ways a system can define the COR:

  • A PDF capture of the on-screen appearance of the file submitted, associated with the signature, the date and time of submission, and a hash value of the file submitted
  • The submitted data as stored in a database, associated with the signature and the date and time of submission
  • A print-out of the submitted data, including the signature and the date and time of submission
Defining the COR
Example Solutions Solution A
PDF Capture of the Submitted File
Solution B
Data in a Database
Solution C
A Paper Print-Out
Opportunity to Review the COR Requires making the PDF available online or sending it to the signer or submitter—as an email attachment or by other means—assuming the PDF captures a human-readable format. Requires: (1) system functions to put the data into a human-readable format; and (2) making the formatted data available online or sending it to the signer or submitter by other means, such as an email attachment. Requires procedures to: (1) receive requests; (2) produce paper copies; and (3) deliver the copies.
COR is Shown to be "True and Correct" Requires a demonstration of the integrity of the PDF file, for example, by showing that it has been secured against tampering or that a hash value calculated from the file matches the hash calculated when it was received. Requires a demonstration that: (1) the processing that placed the data in the database did not, in any way, affect its informational content; and (2) that the database has been secured against tampering and any undocumented changes. Requires procedures to: (1) produce an accurate print-out of the submittal; (2) certify the print-out's accuracy; and (3) secure the print-out against any tampering or destruction.

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