US Election Assistance Commission - Voluntary Voting System Guidelines Vote
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Name :   Ron Crane
Organization :   N/A
Post Date :   9/30/2005

Section Comments
Section :  6.8.5.1.1
Page no. :  
Line no.:  
Comment :  11a.

Along these lines, the Guidelines are ambiguous about the permissibility of certain forms of VVPB. Vol. I, §6.8 appears to allow it, and Vol. I, §6.8.5.1.1 explicitly refers to a system where "the voter is responsible for depositing a paper record in the ballot box," though there is a potential problem with Vol. I, §6.8.4.7, which says:

The voting system should not record the electronic record as being approved by the voter until the paper record has been stored.

In VVPB the voter leaves the voting station, then deposits the ballot in the ballot box, so VVPB systems that retain an electronic audit record technically violate this provision.
However, it's a "should not" instead of a "shall not". Combined with the mention in Vol. I, §6.8.5.1.1,

this might provide enough of a loophole for VVPB, but the Guidelines should recognize and legalize VVPB explicitly.