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When is a memo to file acceptable supporting evidence?

See the FLETA Procedures and Standards Manual 2020 Edition states:

If the TO had no opportunity to employ a particular directive/policy as it relates to the standard for a specific year(s), a Memo to File signed by the AO, or designee, attesting to that fact, is sufficient. A Memo to File cannot be used in place of actual evidence. (pg. 17)