Comments & Submissions

The comment identifies Exhibit B as the Supplement's oversight exhibit and proposes additions that make the object of oversight, the accountable parties, and the decisions on record more explicit.

Five recommendations address program scope; accountability, exclusions, and competency; ratified risk tolerance; authority to operate; and escalation and disclosure. The companion document supplies proposed checklist language, with one amendment, seven new entries, and one optional assurance item.

The full comment also addresses provisions in Exhibit C and the senior officer attestation in the separate third-party vendor instrument. The proposed additions are the Center's text, not amendments adopted by the NAIC.

The Center proposes a chartered oversight program that identifies what an organization governs, who is accountable, who authorizes a deployment, and who can withdraw that authority.

The comment supplies proposed Practice 13 text in the format of the August draft, indexed comments, responses to reviewer questions, and a comparison of accountability mechanisms across critical infrastructure sectors. A separate two-page summary presents the central finding and proposal.