Just saying....
It seems 'silly' that the Change Name functionality is on the Account management page when it specifically states you need to buy a form for 100c. It would be much better / make more sense / etc. if the form had to be 'bought' at the Bureaucratic Hall instead. It should probably require you to already have completed papers (which in turn requires BA1). It might even depend on BA2 which is needed for permits (which name changing sounds a lot like).
Admittedly this limits name changes to those who've actually played the game a little to get papers or whatever, but that doesn't strike me as a big issue, they've got a play enough to get 100c anyway...