Comment on FR Doc # 2026-12205

Comment of Scott Sims, Founder, Rubric Protocol (Echelon Intelligence Group LLC), re Notice-MVAC-2026-01; Docket No. 2026-0331; Sequence No. 1. GSA has correctly identified attestation and traceability as the safeguarding mechanisms for LLM systems processing Government Data. This comment addresses one structural gap: as drafted, every evidentiary artifact the clause depends on — the attestation in (d)(3)(ii), the audit trail in (f)(4), and the processing logs in (e)(4)(ii)(E) — is produced, held, and controlled by the party whose conduct it documents. The clause specifies who must attest and what must be logged, but not the evidentiary properties those records need to survive adversarial review: independent verifiability, tamper evidence, and retention outside the operator’s unilateral control. The attached narrative (PDF) provides four recommendations with suggested clause language, each phrased permissively (“where practicable,” “such as”) and grounded in established practice: RFC 9162 Certificate Transparency, SEC Rule 17a-4 retention, RFC 3161 timestamping, NIST SP 800-86, and EU AI Act Article 12. It includes a direct response to Specific Question 5: covert modification defeats self-reporting by construction, and the workable control is cryptographically verifiable model version lineage checked at audit time. The attached spreadsheet presents the same recommendations in GSA’s requested matrix format (paragraph, exact language, suggested language, comment, citation). I consent to public posting of this comment in its entirety.