Another theory that I have developed over the years.... There are exceptions,that may be explained...
My theory was/is... the awards for infantry Regiments were initially approved at Korps level, but some time in 1916 the responsability was transfered to Divisional level.
This is based on viewing hundreds and hundreds and hundreds of documents.
There are obvious exceptions that had been bugging me... the 4th ersatz Division awarded from the start of the war... but as I found out this week, the 4th "reinforced" division was actually a Korps.
There are also some Korps that were awarding in 1917 and 1918...
My theory, based on nothing concrete, is that when the standard Korps System gave way to the more flexible Generalkommando z.b.V., the transfer of divivions became more frequent than with the older Fixed Korps structure, and the passing up of proposals from Comapny, battalion, Regt, Div, Korps was no longer practcle, especially if a division changed sectors and was under a different command... so the responsabilty was passed down to Divisioanl commanders?
Any thoughts?