For triplicate code 00-04-80, (assigned risk binder – without location(s) within the jurisdiction), Oregon creates a new coverage period. We don't assume that a PC2 follows, especially when it says "without locations in the jurisdiction." (Most of the time a policy to replace the binder does have PC2 records but a policy could be submitted with just a PC1 and that is ok.)    

Usually what follows a binder is a policy transaction (which is PC1 and maybe includes PC2s), not an add employer transaction (that's only PC2). The PC2 should be added as the effective date of the transaction (could be policy effective date, state effective date, or add employer effective date). You're correct in assuming that the filing of the binder should not initiate any late filing compliance action. Additionally, lots of transactions could come in after the initial binder--that's just establishing coverage. Many actions could come after that.

Please let me know if you need clarification or need more information. My email is jennifer.bertels@dcbs.oregon.gov