Comment on FR Doc # 2026-12205

FERZ, Inc. submits the attached comments on the draft GSAR clause 552.239-7001, Basic Safeguarding of Data Within Large Language Model Artificial Intelligence Systems, published at 91 FR 36559 on June 17, 2026. This submission replaces two earlier submissions made on July 15, 2026: tracking number mrm-3apu-ut38, posted as Comment ID GSA-GSAR-2026-0331-0015, which through our error omitted the spreadsheet attachment, and tracking number mrm-3d9d-p29c, which contained both documents but has not been posted. The substance of the comments is unchanged. Both attachments are included here: the narrative comment and the spreadsheet-format table GSA requested. We respectfully ask that this submission be treated as FERZ, Inc.'s operative comment and that Comment GSA-GSAR-2026-0331-0015 be disregarded or annotated as superseded. FERZ, Inc. supports GSA's effort to establish a consistent Government-wide baseline for safeguarding Government Data processed by LLM systems, and we appreciate the substantial improvements reflected in this draft. Our comments make one structural observation and offer thirteen targeted recommendations. The observation is that the clause specifies, in considerable detail, evidence of process, and does not specify evidence of authorization. An attestation establishes what a contractor represents. Monitoring and traceability establish what a system did. Neither establishes whether a consequential action was authorized before execution. Four of the recommendations require no policy change. Two of them identify paragraphs (c) and (d) as omitted from all four flowdown supplemental clauses. One resolves a conflict between paragraphs (e)(4)(ii)(E) and (f)(4)(iii). The remaining recommendations are drafted as technology-neutral performance requirements. None specifies a vendor, model, architecture, or cryptographic method. The comments respond to each of the five questions posed in section C of the Supplementary Information, including Question 5 on foreign ownership and control. Neil Nair Co-Founder and Chief Business Officer FERZ, Inc. McLean, Virginia info@ferz.ai