Skip to Main Content
, ,
May 1, 2023

New Contractor Authorized Signatory Listing (CASL) Forms

The text "Electronic Signatures", overlain on a checkmark and a light green field reminiscent of the DocuSign branding

On Monday, May 1, the Office of the Comptroller and the Operational Services Division have launched a new process for departments to complete the Contractor Authorized Signatory Listing (CASL) Form, based on business type. 

Important changes include: 

Resources  

These resources are available on the CTR Intranet Electronic Signatures page.

About the CASL Form

The CASL Form is used to validate authorized signatories to protect vendors and the Commonwealth from fraud.  

All Contractors must provide a listing of individuals who are authorized as legal representatives of the Contractor who can sign contracts and other legally binding documents related to the contract on the Contractor’s behalf. 

Frequently Asked Questions

When do the new CASL Forms take effect?

The new CASL Forms should be used for all new contracts executed on or after May 1, 2023.

How do the CASL Forms differ from the previous version?

The Contractor Authorized Signatory List (CASL) is now two different forms based on the vendor’s IRS Form W-9 tax classification. There is now:

  • A CASL Form for corporations, which can be executed electronically; and
  • A CASL Form for sole proprietors, which requires a wet signature and a notary certification.

In addition to the authorized signatory’s name and title, the new forms now capture the signature, email address and phone number of the signatory.

 

Do I need to request a new CASL Form for my existing contracts?

A department can request a new CASL Form at any time during the contract period.  The new CASL Form is required for new contracts executed on or after May 1, 2023, and recommended for contract amendments and renewals signed on or after May 1, 2023.

Why do we have to use a CASL Form?

The CASL Form serves two important purposes:

  1. To meet contract and payment legal requirements.
    Departments must identify “authorized signatories,” who are the individuals who are legally authorized to sign contracts, amendments, and other legal documents under a contract such as the Standard Contract form, IRS Tax Form (W-9), banking and payment forms (Electronic Funds Transfer Agreement Form), statements of work (SOW) and contract amendments.
  2. Fraud prevention.
    The CASL Form is a tool to protect both vendors and the Commonwealth from fraud. Fraudsters continue to attempt to misdirect payments by submitting fraudulent invoices or banking changes to misdirect funds to the fraudster’s account.

What are the vendor’s responsibilities with respect to the CASL Form?

Vendors must ensure that key contract information is up to date, including notifying every department with which they do business of any changes to the CASL authorized signatories.  Failure to keep an updated CASL Form on file can subject both the vendor/payee and the Commonwealth to fraudulent misdirection of payments or contract information. The information on the CASL Form will be used to validate requests for changes.

What are the responsibilities of departments with respect to the CASL Form?

The CASL Form is used as part of the validation process for any contract to ensure that any changes are made by an authorized signatory.  The Office of the Comptroller relies upon departments to submit accurate information when completing a vendor/customer registration or modification. In addition to verifying the information submitted in the Massachusetts Alternate Form W-9 and Electronic Funds Transfer (EFT) Authorization Form, departments must verify that the registration or modification request is being made by an authorized signatory of the vendor/payee.

Departments must validate authorized signatories as part of any change request. Following these two steps will ensure that the person requesting the change is authorized to do so:

  1. Validate authority to make the change.
    Validate that the person making the request is listed on the CASL Form as authorized to make changes.  If not, you must contact one or two of the listed individuals on the CASL Form to validate the request. If the CASL Form lists an individual no longer working for the vendor, the vendor must update the CASL Form with authorized signatories.
  2. Validate identity.
    To validate that the authorized signatory listed on the CASL Form is the vendor’s authorized signatory and not a fraudster, departments should:

    • Use information submitted as part of the official procurement and contracting process to validate authorized signatories, including the CASL Form (do not rely solely on electronically submitted documents requesting the change).
    • View the signatory’s government-issued ID with picture over Zoom, FaceTime or Teams.
    • Contact the main office number (what you have already on file, not what is sent in a change request) and state that you are validating the identity of a contractor for changing contract information and validate that the employee works there and is in the position they have listed. Record the name of the person that validated the information.

Where do departments and vendors store the CASL Forms?

CASL Forms are required to be part of the official contract file. The official contract file is required for legal contract purposes and public records purposes.

The department must make the CASL Form available (securely) to any authorized staff who are reviewing and signing off on contracts, amendments, any non-material changes, invoices, and any changes to vendor information. The department must implement internal controls to ensure that the two-part validation process is performed for any changes (and documented for audit purpose).

How long do the CASL Forms need to be kept?

CASL Forms must be maintained by the department and the contractor for a minimum of six years following the last payment under the contract. Departments should maintain copies of both current CASL Forms and changes. The CASL Form may be stored in paper or electronic format.