Comment on FR Doc # 2026-12205
DAY1044 SolutionsSupportBusiness
Summary: DAY1044 Solutions, a small business cybersecurity and AI consulting firm, supports the proposed GSAR clause regarding data safeguarding in LLMs. They recommend specific revisions to ensure that compliance obligations are realistically achievable for small businesses, specifically by aligning requirements with the roles of system integrators and commercial market standards.
DAY1044 Solutions, a Service-Disabled Veteran-Owned and Woman-Owned Small Business providing cybersecurity and AI consulting services headquartered in Washington, DC, respectfully submits the attached comments on Notice-MVAC-2026-01, Docket No. 2026-0331, proposed GSAR clause 552.239-7001, Basic Safeguarding of Data Within Large Language Model Artificial Intelligence Systems (LLMs).
We comment from the perspective of a small business that would itself perform the LLM System Integrator role as defined in paragraph (b) of the proposed clause. Our submission supports the clause's narrowed scope, role-based NIST AI RMF-aligned structure, and data protections, and offers five specific recommendations with suggested replacement language:
Add a documentation-based due-diligence pathway at (d)(3)(iii), as small businesses cannot practicably obtain bespoke attestations from LLM Developers and System Operators (responds to Questions 3 and 4);
Allocate the paragraph (j)(1) unbiased AI obligations by role and span of control, consistent with the clause's own role framework (responds to Question 3);
Conform (j)(2)(ii) to the "commercially available and technically feasible" standard already used at (f)(7)(vi) (responds to Question 2);
Define or provide illustrative examples for "incidental to the primary purpose" at (a)(1)(ii)(B) (responds to Question 1);
Add an express exception to (e)(4)(ii) reconciling the human-access restrictions with the human-oversight obligations of (f)(4) and OMB M-25-21 (responds to Question 2).
Two attachments are included per the format requested in Section C of the notice: (1) a comment letter presenting the full analysis, and (2) a comment matrix in spreadsheet format identifying the page number, paragraph, exact language, suggested language, comment, and citations for each recommendation.
Mikini Williams, Founder & CEO, DAY1044 Solutions