Sep. 22, 2026
To: Subject: Public Comment for the Administrative Record: File Number S7-2026-25 URGENT FILING FOR LEGISLATIVE AND ADMINISTRATIVE OVERSIGHT REVIEW DATE: September 21, 2026 TO: Secretary Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 FROM: Brittney Carrine Boyd Lead Analyst and Consultant Cold Blood and Steel Consulting Milwaukie, OR 97267 SUBJECT: Public Comment for the Administrative Record: File Number S7-2026-25, Electronic Delivery of Information Under the Federal Securities Laws To the Secretary, Regulatory Review Officers, and Congressional Oversight Committees: This organizational filing is submitted under legislative oversight parameters to expedite the review of systemic vulnerabilities in federal data collection frameworks. This comment is formally submitted on behalf of Cold Blood and Steel Consulting to be entered into the administrative record for File Number S7-2026-25 concerning Regulation E-Delivery and the Electronic Delivery of Information Under the Federal Securities Laws. As the Securities and Exchange Commission proposes to transition the default delivery method of required regulatory disclosures from paper to electronic delivery, the structural integrity of the digital data being transmitted becomes paramount. Modernizing the delivery mechanism is administratively insufficient if the underlying financial data and regulatory filings being delivered remain vulnerable to systemic degradation or fraudulent reporting. Through extensive forensic data analysis utilizing Benford's Law distribution models, our firm has evaluated the statistical reliability of federal reporting frameworks and financial schedules. The analytical findings demonstrate that current information collection methodologies require enhanced structural validation. We formally advise the Commission that any shift to default electronic delivery must be accompanied by the implementation of mathematically validated auditing protocols within your data intake and processing frameworks. Integrating advanced forensic distribution models will immediately identify reporting anomalies, validate the integrity of the submitted electronic data, and ensure that the disclosures being delivered to investors and regulatory bodies are rigorously verified. Ensuring the accuracy of these electronic records is critical to fulfilling the Commission's mandate to protect investors, maintain fair and orderly markets, and facilitate capital formation. We request that this comment be applied to the administrative record for File Number S7-2026-25 to ensure immediate compliance with federal oversight mandates. Respectfully submitted, Brittney Carrine Boyd Lead Analyst and Consultant Cold Blood and Steel Consulting