Relating to electronic submission and delivery of public securities and records of proceedings for those securities.

Contracts

• Engagement Letters: Bond Counsel must update engagement letters to explicitly state that filings will be electronic and that the issuer consents to the use of electronic signatures for all closing documents.
• Underwriting Agreements: Representations regarding the valid delivery and registration of securities must be amended to reflect electronic registration and inter-agency transfer between the OAG and Comptroller.
• Vendor SLAs: Verify that third-party e-signature platforms (e.g., DocuSign) guarantee compliance with the Texas Uniform Electronic Transactions Act (TUETA).

Hiring/Training

• Staff Training: Paralegals and closing teams must be trained on the specific OAG submission portal or digital protocol immediately following the December 1, 2025 guidance release.
• IT Support: IT departments must ensure document generation software preserves metadata and allows for the export of fully searchable transcripts.

Reporting & Record-Keeping

• Submission Format: All transcripts, credit agreements, and public securities must be submitted electronically. Physical hand-offs to the Comptroller are eliminated; the OAG will transfer approved files digitally.
• Retention Policy: Update internal retention policies to designate the electronic file as the "authoritative copy" rather than a physical original.

Fees & Costs

• Budget Impact: No new statutory fees. Expect operational savings on printing, binding, and courier services.
• Software Costs: Potential minor costs to upgrade e-signature or PDF compilation software to meet OAG technical standards.