US Election Assistance Commission - Voluntary Voting System Guidelines Vote
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Name :   Kathy Dopp
Organization :   National Election Data Archive
Post Date :   9/30/2005

Section Comments
Section :  A1D
Page no. :  D-6
Line no.:  15 - 19
Comment :  RE: Appendix D (your comment form does not permit Section: Appendix D or Section: D-1 to be entered)

Why "(albeit loosely)"?  

Optical scan voting systems most definitely "produce a record that the voter verifies directly with the voter's senses which is preserved for auditing or counting".  Because optical scan ballots use a bar-code there are two records on the same ballot and the electronic counts can be verified "independently" of any insiders within the voting system.