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How to track custom form usage with Sign-On:Audit Level set to form level?

E-Business Suite 12.2.5

We have set Sign-On:Audit Level to Form at the site level to track form usage across the organization. This information has been requested to review segregation of duties in regards to EBS access.

Standard forms are tracked as expected, but the custom forms are not. Development reviewed note 1067473.6 and confirmed that the FND_STANDARD.FORM_INFO call in the WHEN-NEW-FORM-INSTANCE trigger is present.

Any guidance would be appreciated.

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