No. And the test is relevant.
See Post #596 ... :-)
The problem is that she never actually defines "vital records".
Point blank, there is no attorney that would ever accept her statement regarding "vital records" at face value, without immediately following up with a litany of questions to establish exactly what kind of document ( or documents ) the statement was predicated upon. Who issued or wrote the document(s); when were they originally issued or written, and by whom.
They would then ask to have a certified/notarized copy of that document sent to them. That's a given.
Fukino has provided herself with just enough wiggle room so that if the proverbial s*** ever hits the fan, -she call fall back and claim that she never actually attempted to validate a specific COLB.