BSA appreciates NIST’s focus on this important issue but are concerned that the current draft may not achieve these goals. We provide recommendations below on how to enhance the Documentation Outline to enable the proposed standard to work most effectively in practice. 

Specifically, we recommend that NIST: 

• Adopt a tiered approach to transparency documentation;
• Revise the outline to address the need to protect sensitive proprietary information; and
• Ensure the “Zero Draft” proposed documentation standard complements existing transparency efforts and provides an interoperable solution.