Comments Submitted to Standards and Consultation Processes
Sep 30, 2026 - CPMI-IOSCO Discussion Paper - FMIs’ Reliance on Third-Party Service Providers: Challenges and Risks - Examines whether separately contracted services represent genuinely independent failure paths, proposes a dated dependency reconciliation approach, and distinguishes contractual entitlement from exercised operational capability. Questions 1, 2 and 5, with Questions 3 and 4 addressed together. Public comment submitted in personal.
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Sep 9, 2026 - UK Call for Evidence (DSIT) - Data Regulation in the Age of AI and Other Data-Intensive Technologies
Identifies an evidential gap between compliance records and the processing those records are capable of observing, and proposes five changes that require no new legal instrument. Themes 1, 3 and 5. Response submitted 9 September 2026.
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Sep 9, 2026 - NIST AI 200-2 ipd - The TEVV Athlon Framework for Evaluating AI Systems
Identifies a temporal and evidentiary gap between measurement and the authority that acts on it and proposes five additions in the framework's own vocabulary. Public comment submmited 9 September 2026.
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