That's right, DAT. You simply can't trust a gov't official who tells you to go ahead and do it some other way than the letter of the law. What would motivate this private business to withhold the letters anyway? He's looking at a shit sandwich on Jan 2. Not fair to the employees, either, jerking them around like that.
We had a slightly complicated sale of an asset recently. The DMV were all clustered over it. One clerk said to make a bill of sale of zero and "gift" it, even though money did indeed change hands. My husband went ballistic, "you're asking me to lie to the government, and trust you that it's just fine??!!" What a mess. All better now though.