If there is not requirement or penalty for not signing, will all federal employees start refusing to sign a OF-109 form when they leave? Why wouldn't they? There is apparently no rule requiring it and no penalty for not signing.
While State’s Foreign Affairs Manual declares that “a separation statement will be completed whenever an employee is terminating employment,” Psaki insisted that Clinton’s departure without signing the form didn’t run afoul of any directive.
“We’re not aware of any penalty for not signing it,” Psaki said. “It’s not a violation of any rule.”