32.1.6.8.1. and CCDM 32.2.7.2. If those reviewing the document provide comments or
make revisions, the file name for the document that is returned to the drafting attorney
should reflect who made the comments or revisions and the date of the comments or
revisions. Once those reviewing the document are ready to clear it, they should reply to
the clearance email stating their approval. The drafting attorney then should type the
name of the reviewer, the reviewer’s office, and the date of approval into the pink
clearance sheet or the Background Information Note (BIN) after each approval is
received. Alternatively, the pink clearance sheet or the BIN may be digitally signed to
document approval.
Use of Digital Signatures on Office of Chief Counsel Documents
Effective immediately, digital signatures may be used to sign any Office of Chief
Counsel document, including but not limited to: published guidance, Chief Counsel legal
advice, letters to the Department of Justice, Action on Decisions (AODs), and Private
Letter Rulings (PLRs). Methods of digital signatures include:
• Converting a document to a PDF and adding a signature in Adobe
Acrobat;
• Scanning an image of a signature and adding to the document; or
• Adding “/s/” and the person’s name to the text of the document and then
locking the document as provided in Exhibit 1.
Procedure to Obtain Digital Signatures on Regulations
Regulations may be signed digitally in accordance with Federal Register requirements,
which are attached as Exhibit 1. The Office of the Federal Register requires that
documents submitted for publication in the Federal Register be signed in Microsoft
Word by adding an invisible digital signature. This process prevents the text of the
document from being revised after the invisible digital signature is applied.
Consequently, signing the document must be the last act performed before the
document is submitted to the Federal Register for publication.
A document is ready for digital signature once the regulation has been approved for
publication by the Office of Chief Counsel, the Office of the Deputy Commissioner,
Services and Enforcement (DCSE), and the Treasury Department and prepared for
submission by the assigned Federal Register Liaison (FRL) in the Publications and
Regulations Branch of the Legal Processing Division of Procedure and Administration.
At that point, no more changes can be made to the document.
To digitally sign a Microsoft Word document, the following steps must be performed in
the following order:
1. After the document is approved by Treasury, the document, pink clearance
sheet, and record of Treasury approval is e-mailed by the Associate Office to the
assigned FRL to prepare the document for signature.