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Reps & Certs / Foreign Exemption from CAS / QMAC

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When a foreign concern (UK; has a QMAC) is filling out the CAS Notifications and Representations and is claiming a foreign concern exemption , what is the compliant way to answer the question regarding the filing a CAS Disclosure Statement?  Should they answer the question with information about their QMAC submission or leave the question blank since they do not have a CAS Disclosure Statement?

Thanks!

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I would put N/A because you don't want to be accused of misleading reviewers into thinking you actually filed a CASB DS-1. In the proposal narrative, you can explain that you filed a QMAC and it was reviewed and found to be adequate by CAAS.

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Agree with here_to_help that you should stay away from asserting you submitted something you didn't. However,  if I were going to use "N/A" I would say something more like  "N/A, exempt per (below?)" Point being that some person may just be reading the certificate for compliance decision and not reading the proposal to find out why you are asserting it is not applicable. For me, perhaps your post could have displayed the exact language of the pertinent CAS solicitation because if it were worded such that you are not required to answer provided you are claiming an exemption, I would tend to not say anything. If the CAS Disclosure Statement item was one of a number of items in the same paragraph, and you inserted "N/A" for that item but not for others, you may be shooting yourself in the foot if those were also N/A due to your claimed exemption. Could depend on where you inserted "N/A."

Edited by Neil Roberts
typos 2nd and last sentence

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