AFAICT whilst the forms must be signed annually, that does not mean that the form must be signed at the start of each calendar year.
The current COI file layout assumes a directory for each calendar year. I think that is going to cause complications. I think the directory structure should be flattened. When an officer signs a new form, it should replace the old one (if any). The signing date could be recorded in a separate index file. Or maybe the entry in the index file would be sufficient to record agreement?