A statement of position or a statement of controversion as provided for in Texas Civil Statutes, Article 8306, §18a(a), shall state fully and in writing the grounds for refusal to commence paying compensation. These grounds must be based on actual investigation of the claim and stated in sufficient detail so as to be compared with the position taken by the carrier at the prehearing conference. It is insufficient to simply state a conclusion, for example, "liability in question," "compensability in dispute," or "under investigation." When a carrier files an insufficient statement of controversion or statement of position, the board will issue a complaint report to the carrier through its designated Austin Industrial Accident Board representative. The carrier will have 30 days from the date of receipt of the complaint report to respond in writing to the charge. The board will evaluate the carrier's response. If a majority of the board members determine that a violation has occurred, the violation may be used to establish a record of general business practice, in accordance with Texas Civil Statutes, Article 8306, §18a(d). A failure to respond to the complaint report within 30 days will constitute an automatic violation.