May 8, 2026
Executive Summary As a professional systems auditor, I am submitting this comment to address the "sufficiency of other audit trails and related data sources" as solicited in Release No. 34-105251. This submission provides a primary case study regarding the systemic failure of third-party compliance audit trails to prevent the retroactive forgery of material safety and operational data. 1. The "By Design" Deficiency in Digital Audit Trails In response to the Commission's inquiry into the technical design and scope of audit trails, I wish to highlight a pervasive and intentional flaw in third-party compliance software (specifically the FormFox ecosystem). Forensic analysis of FormFox Workset ID [redacted] revealed that these systems are frequently engineered to be "unsigned by design" regarding donor-facing receipts. This architectural choice creates a "dark window" in the audit trail that allows for: • Retroactive Forgery: The application of digital signatures after a transaction has concluded without contemporaneous verification. • Signature Stripping: The deliberate omission of collector certifications from secondary records, as admitted in writing by [redacted]. • Temporal Impossibilities: The generation of "certified" records dated after an individual's termination, proving that the audit trail is not being captured "at or near the time of the act". 2. Necessity of Granular Metadata Standards The Commission asks whether existing audit trails are sufficient to reflect demonstrated regulatory needs. Based on my forensic audit, current trails are insufficient because they lack mandatory, immutable links between User IDs, IP addresses, and UTC timestamps. Without these specific metadata pillars, entities can manipulate the "Consolidated Audit Trail" by backdating records to facilitate multi-billion dollar M&A transactions, such as the pending $1.7 billion acquisition of Delta Utilities. In this instance, the lack of a granular audit trail has been leveraged to conceal federal liabilities under 18 U.S.C. § 1001. 3. Impact on SEC Rule 21F-17 (Whistleblower Protection) Insufficient audit trails are currently being utilized as tools of Rule 21F-17 violations. When a system is "unsigned by design," it allows management to characterize a whistleblower’s identification of data gaps as "harassment" rather than "forensic discovery". I have personally experienced this impediment, including a "Cease and Desist" threat from a regional official intended to stop the reporting of these audit trail failures to high-level Commission personnel. Conclusion The Commission must establish mandatory standards for "other audit trails" that require contemporaneous, signed verification at every stage of the chain of custody. A system that is "unsigned by design" is not an audit trail; it is an instrument of fraudulent misrepresentation. Respectfully submitted, Bryan Keith Dixon Prairieville, Louisiana