[IYAS9YAS]

The OF part of OF-109 is Optional Form. Optional Forms are defined here: “Optional Form” means a form developed by a Federal agency for use in two or more agencies and approved by GSA for non-mandatory Government-wide use.

http://www.gsa.gov/portal/forms/download/117242

It appears that only Departmental Regulation to sign the form, but not any law, was violated.

I may be, and often am, wrong, though.

[FR_addict]

I was a little confused about what the optional meant too, but I think it means that the GSA doesn’t require it of all departments, but if State requires it, you must sign. According to the info I found the State Department requires the form to be signed and returned when the personal ID is returned.