Comment on FR Doc # 2026-09067

USAX (usax.com) is a veteran-owned Texas small business. We respectfully submit these comments in support of the proposed rule. USAX builds provenance-verification technology: infrastructure creating persistent, verifiable records of beneficial ownership and source of capital. USAX has been selected for negotiation and funding by the U.S. Air Force and U.S. Space Force under a Direct-to-Phase-II SBIR (topic SF254-D1201). We comment as a developer of the analytic capability this rule will require and as a prospective covered contractor. The definitional foundation is correct. Defining "beneficial owner" by reference to 17 CFR 240.13d-3 (clause 252.240-70YY) rightly anchors defense supply-chain security to the established capital-markets standard. Adversarial access to the defense industrial base is, at bottom, a capital-markets problem of layered funds, intermediate entities, and cross-border structures. Properly defining this problem is the first step to solving it, and it should be verified with capital-markets-grade infrastructure. Disclosure without analytic verification will make NISS eligibility the bottleneck for awards. Proposed 240.27X-4 conditions award, modification, and option exercise on "eligible" status, making DCSA's adjudication speed a precondition for contract velocity across an estimated 37,740 entities (21,511 of them small businesses, per the preamble). GAO-26-107861 (April 2026) found DCSA's own capability requirements call for analytical tools to manage risk across the defense industrial base, including "artificial intelligence-enhanced data aggregation analysis," and that these modernizations "have not been implemented to date"; GAO recommended enhanced analytic tools and DoD concurred. SF 328 intake is self-certified; independent, continuous verification is what protects good-faith actors and surfaces adversarial ones. We recommend the final rule, and PGI pair the expanded disclosure regime with analytic verification capability (ideally persistent verification) at DCSA, and that DoD consider provisional or time-bound eligibility procedures while the initial adjudications process, so the gate does not become a barrier to entry for small businesses, for which award delay is existential. Clarify the knowledge standard and recognize automated monitoring. Clause 252.240-70YY(d) sets reporting clocks of three business days, yet beneficial ownership can change through events upstream of the contractor (fund-level transfers, secondary sales, convertible instruments) without the contractor's contemporaneous awareness. We recommend the final rule (a) clarify that reporting clocks run from actual knowledge or reasonable discovery, and (b) recognize automated, event-driven beneficial-ownership monitoring as an acceptable means of meeting the disclosure-currency, update, and flow-down duties in 252.240-70YY(c)-(e). This matters for primes verifying dozens or hundreds of subcontractors, for small subcontractors without compliance staff, and for DCSA itself. The preamble's ten-minute verification estimate holds only where verification is technology-assisted. Commercial capability exists, and Congress has provided the adoption path. SBIR-funded provenance-verification platforms, including USAX's capability under development for the Air Force and Space Force, are built to map beneficial-ownership chains, screen sources of capital, and produce auditable, adjudication-ready evidence at the rule's scale. SBIR Phase III authority (15 U.S.C. 638(r)(4)) permits any federal agency, including DCSA, to procure such technology rapidly, including on a sole-source basis. We encourage DoD to leverage this authority so implementation capability arrives on the rule's timeline. Small-entity note (Regulatory Flexibility Act): the principal small-entity risk is not the disclosure burden but adjudication latency at the eligibility gate; the mitigations above address it directly. USAX stands ready to demonstrate this capability to DCSA and other implementing offices. We thank the DAR Council for its work on this rule. Respectfully submitted, Chad Grills, CEO, USAX