(2) Additional Requirement for Answer: In addition to the specific admission or denial of each material allegation in the petition, the answer shall contain the following:
(A) Clear and concise lettered statements of the facts on which the Commissioner relies to establish that, in the administrative proceeding, the Commissioners position was substantially justified;
(B) A statement whether the Commissioner agrees that the petitioner substantially prevailed in the administrative proceeding with respect to either the amount in controversy or the most significant issue or set of issues presented in the administrative proceeding;
(C) A statement whether the Commissioner agrees that the amount of administrative costs claimed by the petitioner is reasonable;
(D) A statement whether the Commissioner agrees that the petitioner meets the net worth requirements as provided by law; and
(E) The basis for the Commissioners disagreement with any such allegations by the petitioner.
