PUBLIC COMMENT SUBMISSION

To: csf@nist.gov (published also at blog.mortgagequote.ca)
Re: NIST SP 1347 (Initial Public Draft) — NIST Cybersecurity Framework 2.0: Informative References Quick-Start Guide
Comment Period Closing: May 6, 2026, 11:59 PM EST
Date of Submission: [INSERT DATE]
Companion Document: This letter constitutes Part 1 of MQCC®'s submission. A companion document — From NIST CSF 1.0 to 3.0: The Arc of Correction and the Pathway Forward — MQCC® BIT™ NIST (BITNIST™) / NIST CSF 3.0 Structural Proposal — is enclosed as Part 2, presenting a skeletal architecture for consideration in future CSF revisions. Both documents should be read together.

From:
A. K. (Anoop) Bungay
Principal Broker & Governor
MQCC® Bungay International (BII™), Washington, DC, USA
MQCC® MortgageQuote Canada Corp., Calgary, Alberta, Canada
info@mqcc.org · www.mqcc.org · www.cyberlockchain.com

Thank you for the opportunity to comment on the Initial Public Draft of SP 1347, the CSF 2.0 Informative References Quick-Start Guide.

MQCC® is a U.S.-registered (Washington, DC) and Canadian private-sector organization that has operated an integrated cybersecurity framework cross-mapping international, U.S. federal, and Canadian federal cybersecurity standards since October 2018, built upon an ISO 9001 quality management system continuously certified since May 9, 2008. Our cybersecurity governance architecture — placing governance as the superordinate function above operational cybersecurity functions — predates the structural elevation of GOVERN in CSF 2.0 by six years. Our cybersecurity services operate under the registered trademark CYBERLOCKCHAIN® (Conformity-Yoked Bungay Enterprise Risk-based Logic Order Command Kernel; Cyber/Non-Cyber Harmonized Artificial/Non-Artificial Intelligent Network).

We offer the following comments organized around the three core functions of the guide — finding, filtering, and applying informative references — followed by structural recommendations for the framework itself, an observation on the methodological foundation required to make governance effective, and a note on subject matter expert engagement through the National Online Informative References (OLIR) Program.

Throughout this submission, references to The Anoop Bungay 21st Century Scientific Method™ use the abbreviation AB21CSM™.

A Note on Time-in-Practice and the Development of New Terminology

MQCC®'s 25 years of continuous operation (2001–2026) in governance-first, standards-integrated cybersecurity architecture represents a depth of time-in-practice and time-in-innovation that is, to our knowledge, unmatched in the private sector for this domain. This sustained operational experience has produced a recognition that existing vocabulary is insufficient to describe the architectural and scientific concepts that emerge from decades of standards-based practice.

Accordingly, MQCC® has developed and formally submitted new terminology to the English language record through Collins English Dictionary, including terms directly relevant to this submission:

• Tautologiconformity (submitted April 11, 2026) — the condition in which the output of a standards-based system is self-provingly conformant to the normative input that created it, such that conformity is true by structure rather than by assertion.

• Tautologiconformant (submitted April 11, 2026) — describing a system whose conformity to defined requirements is self-proving by design.

• Conformitivity (submitted January 26, 2026) — the dynamic, self-sustaining capacity of systems to establish, maintain, and enforce conformity to defined requirements over time, expressed as M = Q × C².

• Supersubsumption (submitted January 1, 2026) — the relationship in which a superordinate structure contains and governs a subordinate structure while the subordinate cannot operate independent of the superordinate.

• Conformity Science (submitted January 1, 2026) — the science of transforming stakeholder expectations into reality through standards-based, quality-managed processes.

• Bungay Physics (submitted January 1, 2026) — the branch of conformity science concerned with fundamental laws governing value, action, and state in rule-bound systems across the continuum of space, time, and legal.

• Compound Quality (submitted January 1, 2026) — the compounding effect of quality management over time within a continuously certified system.

• Conformity-bound system (submitted January 12, 2026) — a system structurally yoked to conformity requirements, as distinct from a system that merely aspires to conformity.

These are not marketing terms. They are scientific and architectural concepts that emerged from operational necessity — the existing vocabulary could not describe what 25 years of time-in-practice had built. The companion document (Part 2) employs these terms in its structural proposal for CSF 3.0.

NIST's own history demonstrates this phenomenon: the concept of governance-as-superordinate existed in operational practice (at MQCC® since 2001) long before the framework vocabulary caught up (CSF 2.0, February 2024). The terminology submitted above represents the next generation of vocabulary that the cybersecurity governance field will require as it moves from compliance-based models toward tautologiconformant architectures.

1. FINDING Informative References

The guide presents three consumption pathways: direct download, the CSF 2.0 Reference Tool, and the National Online Informative References (OLIR) Program (https://csrc.nist.gov/projects/olir). These pathways serve organizations well when they are beginning their CSF 2.0 journey. However, the guide would benefit from acknowledging that some organizations have already built and operated their own informative reference cross-mappings in production environments — in some cases for years prior to the publication of CSF 2.0.

These practitioners do not need to find references — they need to validate, update, and contribute what they have already built.

MQCC®'s Integrated Cybersecurity Framework (October 2018) cross-maps CSF Core functions against ISO/IEC 27001, ISO 9001:2015, NIST SP 800-53, Canadian federal regulatory requirements, and workforce competency standards. This mapping has been in continuous operational use. We are prepared to contribute it to the OLIR catalog as a standardized online informative reference submission, but the current guide does not adequately address the pathway for organizations in this position — organizations that are not consumers of informative references but prospective contributors to the OLIR Program.

Recommendation 1: Include guidance for organizations that have existing cross-mappings and wish to migrate them to the CSF 2.0 structure or contribute them as subject matter expert (SME) submissions to the OLIR catalog (https://csrc.nist.gov/projects/olir). The current guide assumes users are consumers starting from zero. Many are producers with years of operational cross-mapping experience ready to contribute.

2. FILTERING Informative References

The guide explains how users can filter references by Function, Category, and Subcategory using the CSF 2.0 Reference Tool. This is useful but incomplete in two respects.

2a. Multi-Jurisdictional Filtering

In practice, organizations operating in regulated industries filter informative references by regulatory jurisdiction — for example, a Canadian federally-adjacent financial institution must filter for references that satisfy both U.S. federal cybersecurity controls and Canadian federal financial regulatory requirements simultaneously. The current filtering model does not address multi-jurisdictional filtering or the layering of regulatory requirements across national boundaries.

This is not a theoretical concern. Organizations operating across U.S., Canadian, and international regulatory environments — as MQCC® does across Alberta, British Columbia, and Ontario under Canadian provincial mortgage regulatory frameworks, while cross-mapping to NIST, ISO, and OSFI federal requirements — require filtering logic that accounts for concurrent jurisdictional obligations.

2b. Governance of AI-Assisted Filtering

The guide discusses how AI tools can support reference data use. We note from extensive field experience that AI-augmented filtering is already operationally feasible — AI systems can cross-reference multiple frameworks, identify conformity gaps, and produce standards-based assessment reports at speeds that manual filtering cannot match.

MQCC® currently operates a Hybrid Human-AI Integrated Quality Management System (HHAIQMS™) in which AI substrates perform framework cross-referencing, gap analysis, and conformity assessment under documented human governance authority. This is not aspirational — it is in daily production use.

However, the guide does not address governance requirements for AI-assisted filtering — specifically, that AI-generated outputs should be subject to human authority, quality management oversight, and documented review before being relied upon for cybersecurity decisions. The speed of AI-assisted filtering is valuable. Ungoverned AI outputs create their own conformity risk.

Recommendation 2: Address multi-jurisdictional filtering use cases, particularly for organizations operating across U.S., Canadian, and international regulatory environments. Additionally, include governance guidance for AI-assisted filtering and analysis of informative references — establishing that AI outputs require human authority, documented review, and quality management system oversight.

3. APPLYING Informative References

The guide introduces how informative references support the development of CSF 2.0 Organizational Profiles. MQCC® offers two observations on application:

First, the elevation of GOVERN as the first, superordinate function in CSF 2.0 is the most significant structural improvement in the framework's history. Organizations that already operate formal governance systems — including quality management systems, risk management frameworks, and workforce competency programs — possess infrastructure that maps directly to the GOVERN function's six categories. The guide should communicate this alignment as a pathway for accelerated adoption: organizations with existing governance infrastructure are not starting from scratch.

Second, the NICE Workforce Framework for Cybersecurity is now embedded as an informative reference across the CSF 2.0 Core. In our experience, workforce competency is the cognitive entry point for applying informative references — before an organization can govern, protect, detect, respond, or recover, its people must possess the knowledge and skills to do so. The guide should highlight the NICE Framework references as a recommended starting point for organizations new to CSF 2.0 implementation, not merely as one reference among many.

Recommendation 3: Communicate that organizations with existing governance infrastructure have a direct pathway to CSF 2.0 adoption through the GOVERN function. Highlight the NICE Framework informative references as the recommended cognitive entry point for new implementers.

4. STRUCTURAL RECOMMENDATION: From Governance to Governance, Management, and Operations

Beyond the scope of SP 1347 but directly relevant to the evolution of CSF 2.0 itself, MQCC® respectfully submits the following structural observation.

The elevation of GOVERN to a superordinate function in CSF 2.0 was correct and overdue. However, it is incomplete. MQCC®'s operational architecture — formalized as CIGMOS™ (Conformity-Integrated Governance, Management, and Operations System)² — recognizes three co-equal functions within the governance tier, not one:

• Governance — direction, authority, accountability, policy, oversight

• Management — planning, resourcing, organizing, coordinating, measuring

• Operations — execution, delivery, performance

CSF 2.0 elevated Governance. It has not yet distinguished Management and Operations as separate, co-equal functions. The framework currently distributes management-class and operations-class activities across its five operational functions (Identify, Protect, Detect, Respond, Recover) without structural differentiation.

This matters for implementation. An organization that conflates management with operations — or governance with management — will produce conformity gaps that informative references alone cannot resolve. The structural separation of Governance, Management, and Operations (GMO) provides the organizational clarity that CSF 2.0 implementers need.

MQCC® has operated the GMO architecture since 2001. We note that every major cybersecurity product on the market — including endpoint detection platforms, SIEM/SOAR platforms, vulnerability management platforms, and emerging AI-powered cybersecurity initiatives — operates exclusively at the Operations layer. No market tool provides Governance. No market tool provides Management. These are organizational functions that must be built by the implementing organization, and the framework should make this structural distinction explicit.

Recommendation 4: Consider the structural separation of Governance, Management, and Operations (GMO) as three co-equal functions within the CSF 2.0 governance tier in future framework revisions. This separation clarifies implementation responsibilities and prevents the conflation of organizational functions with tool-level capabilities.

5. METHODOLOGICAL FOUNDATION: The Requirement for an Educative Scientific Method

Structural separation of Governance, Management, and Operations is necessary but not sufficient. The GMO system must operate within a governing scientific method — otherwise, the three functions become bureaucratic categories without a mechanism for learning, improvement, and institutional knowledge transfer.

MQCC® operates GMO within a methodological framework known as AB21CSM™ — The Anoop Bungay 21st Century Scientific Method™,¹ structured as a Solid Square Pyramid with six vertices:

ENTER · LEARN · WRITE · CREATE · PROVE · IMPROVE

The critical architectural feature of this method is that none of the six vertices is "educate." Education is not a step in the process — it is the substance of the entire structure. The method designates EDUCATIVE™ as the solid mass that fills the pyramid: it operates simultaneously as the precondition (before the action), the in-condition (during the action), and the postcondition (after the action) at every vertex, every sub-vector, and every level.

This distinction has direct consequences for CSF 2.0 implementation:

• ENTER is not merely cognitive awareness — it is structural entry into a pre-existing Standards-based Operating Environment. An organization implementing CSF 2.0 does not begin by learning the framework in isolation; it enters an environment where governance, management, and operations infrastructure already exists and operates. CIGMOS™ is that environment.
  
  

• LEARN, WRITE, CREATE, PROVE, IMPROVE are the vertices through which the organization acquires knowledge, codifies its constitution, builds and executes its systems, verifies conformity, and feeds improvement back to the entry point — continuously.
  
  

• EDUCATIVE™ as the solid mass means that workforce competency (the NICE Framework), organizational learning, and institutional knowledge transfer are not separate activities bolted onto the framework — they are the substance through which every governance, management, and operations function is performed. This is why MQCC® recommends the NICE Framework as the cognitive entry point (Recommendation 3): workforce competency is the educative mass through which the framework becomes operational.
  
  

The relationship between the method and the system is one of SUPERSUBSUMPTION™ — the AB21CSM™ method supersubsumes the CIGMOS™ system. The method contains and governs the system; the system cannot operate independent of the method. Without a governing scientific method, a cybersecurity framework — however well-structured — remains a static taxonomy. With one, it becomes a living, self-improving operational architecture.

Recommendation 5: Consider that governance frameworks require a governing scientific method — a structured approach to organizational learning, knowledge codification, system creation, conformity verification, and continual improvement — to be operationally effective. The current framework provides the taxonomy (what to govern). The method provides the mechanism (how to govern, learn, and improve). Future CSF revisions should address the relationship between framework structure and methodological discipline.

6. THE ROLE OF EXISTING GOVERNANCE INFRASTRUCTURE IN CSF 2.0 ADOPTION

The guide would benefit from explicitly recognizing that organizations with mature quality management systems — particularly those certified to ISO 9001:2015 or equivalent standards — already possess governance infrastructure that maps directly to the GOVERN function. These organizations have documented:

• Organizational context and interested party requirements (mapping to GV.OC)

• Risk-based thinking and risk treatment processes (mapping to GV.RM)

• Roles, responsibilities, and authorities (mapping to GV.RR)

• Documented policies and procedures (mapping to GV.PO)

• Management review and performance evaluation (mapping to GV.OV)

• Control of externally provided processes, products, and services (mapping to GV.SC)

For these organizations, CSF 2.0 adoption through the GOVERN function is not a new build — it is a mapping exercise. The guide should say so.

Recommendation 6: Explicitly acknowledge that ISO 9001-certified and equivalent organizations possess governance infrastructure that maps to the GOVERN function's six categories, and provide guidance for leveraging existing quality management systems as the foundation for CSF 2.0 implementation.

7. CSF 2.0 IN THE CONTEXT OF FEDERAL ACQUISITION AND HIGHER-LEVEL CONTRACT QUALITY REQUIREMENTS

The guide does not address the relationship between CSF 2.0 implementation and the higher-level contract quality requirements established under the Federal Acquisition Regulation (FAR), the Defense Federal Acquisition Regulation Supplement (DFARS), and the Code of Federal Regulations (CFR). This is a significant gap.

When the U.S. federal government procures systems, services, or products where the risk of nonconformance carries critical consequences — defense, aerospace, nuclear, critical infrastructure, and national security applications — the governing acquisition regulations do not merely require cybersecurity controls. They require conformity-assured quality management systems capable of reducing the risk of nonconformance to acceptable levels. Specifically:

• FAR Part 46 (Quality Assurance) establishes the framework for contract quality requirements, distinguishing between standard, higher-level, and critical quality requirements based on the complexity, criticality, and risk profile of the acquisition.

• DFARS 252.246 supplements FAR with defense-specific quality assurance provisions, including requirements for higher-level quality standards traceable to ISO 9001 or equivalent for complex and critical items.

• CFR Title 48 codifies the acquisition regulatory system within which these quality requirements operate.

The implication for CSF 2.0 is direct: organizations seeking to provide cybersecurity services, products, or governance systems to federal agencies — or to any entity operating within federal supply chains — must demonstrate not only that they implement CSF 2.0 controls, but that they do so within a quality management system that meets higher-level contract quality requirements. The GOVERN function's six categories map naturally to this requirement, but the guide does not make this connection explicit.

MQCC® operates at this intersection. Our cybersecurity governance architecture — CYBERLOCKCHAIN®² — is built upon an ISO 9001:2015 quality management system continuously certified since May 9, 2008 (18 years), with cybersecurity governance, AI-assisted conformity assessment, and cross-framework harmonization integrated into the QMS. This is the grade of conformity assurance that FAR and DFARS higher-level contract quality requirements contemplate: not a cybersecurity product, but a conformity-assured governance system in which cybersecurity products operate under documented, audited, continuously improved quality management.

To our knowledge, no cybersecurity vendor currently presents its offerings within the context of FAR/DFARS/CFR higher-level contract quality requirements. The market sells tools at the Operations layer. MQCC® provides the governed, managed, quality-assured environment — at the standard of conformity assurance that critical and complex federal acquisitions demand — within which those tools are deployed, monitored, and continuously improved.

The OLIR Program and CSF 2.0 informative references serve organizations across all sectors, but the guide should acknowledge that for federal acquisition contexts, CSF 2.0 implementation must be situated within — not separate from — the quality management system infrastructure that FAR, DFARS, and CFR already require. Organizations that possess this infrastructure are not merely implementing a cybersecurity framework. They are demonstrating conformity assurance at a level that reduces the risk of nonconformance in critical and complex environments — the very purpose for which higher-level contract quality requirements exist.

Recommendation 7: Address the relationship between CSF 2.0 implementation and federal acquisition quality requirements (FAR Part 46, DFARS 252.246, CFR Title 48). Acknowledge that for critical and complex acquisitions, cybersecurity governance must operate within conformity-assured quality management systems, and that the GOVERN function provides the natural integration point between CSF 2.0 and higher-level contract quality requirements.

8. SUBJECT MATTER EXPERT ENGAGEMENT THROUGH THE OLIR PROGRAM

The National Online Informative References (OLIR) Program (https://csrc.nist.gov/projects/olir) is designed to facilitate subject matter experts (SMEs) in defining standardized online informative references. NIST's ongoing work on CSF 2.0 — and particularly the intersection of AI-assisted analysis, governance architecture, cross-framework integration, and federal acquisition quality requirements addressed in this comment — would benefit from the direct engagement of practitioners who have built, operated, and maintained integrated cybersecurity governance systems in production environments over extended periods.

A. K. (Anoop) Bungay, the undersigned, has led the design, construction, and continuous operation of such systems at MQCC® since 2001 — a 25-year record of governance-first cybersecurity architecture predating CSF v1.0 by thirteen years. Mr. Bungay's specific domain expertise includes:

• AI-Conformity Integration — designing and operating systems in which artificial intelligence substrates perform cybersecurity analysis, framework cross-referencing, and conformity assessment under documented human governance authority, within a certified quality management system. This is the precise intersection that SP 1347 addresses in its discussion of AI-assisted informative reference analysis, and MQCC® is, to our knowledge, the only organization operating this capability in production under ISO 9001 governance.
  
  

• Cross-Framework Harmonization — building and maintaining live cross-mappings across NIST CSF, ISO/IEC 27001, ISO 9001:2015, NIST SP 800-53, NICE Workforce Framework, Canadian federal financial regulatory requirements (OSFI, PCMLTFA), and provincial regulatory frameworks — simultaneously, in a single integrated system.
  
  

• Governance-Management-Operations Separation — operating three co-equal organizational functions (Governance, Management, Operations) as the structural foundation for cybersecurity, predating NIST's elevation of Governance by six years and extending the architecture beyond what CSF 2.0 currently addresses.
  
  

• Scientific Method for Cybersecurity Governance — developing and applying a formal scientific method (AB21CSM™ — The Anoop Bungay 21st Century Scientific Method™)¹ that provides the mechanism for organizational learning, knowledge codification, conformity verification, and continual improvement within cybersecurity governance systems.
  
  

Mr. Bungay would welcome the opportunity to contribute to NIST's ongoing CSF 2.0 development as a subject matter expert, subject to availability and scheduling — whether through the OLIR Program, future public comment periods, workshop participation, or direct advisory engagement.

SUMMARY OF RECOMMENDATIONS

1. FIND: Include guidance for SME contributors with existing cross-mappings — they need migration and OLIR submission pathways, not just discovery.

2. FILTER: Address multi-jurisdictional filtering and establish governance requirements for AI-assisted informative reference analysis.

3. APPLY: Communicate existing governance infrastructure as an accelerated adoption pathway, and highlight the NICE Framework as the cognitive entry point for new implementers.

4. STRUCTURE (GMO): Consider the structural separation of Governance, Management, and Operations as three co-equal functions in future CSF 2.0 revisions.

5. METHOD (AB21CSM™): Consider that governance frameworks require a governing scientific method — integrating organizational learning as the substance of every governance, management, and operations function — to be operationally effective.

6. ISO 9001 PATHWAY: Explicitly acknowledge ISO 9001-certified organizations' existing governance infrastructure as a direct mapping pathway to the GOVERN function.

7. FEDERAL ACQUISITION (FAR/DFARS/CFR): Address the relationship between CSF 2.0 implementation and higher-level contract quality requirements for critical and complex acquisitions, acknowledging that cybersecurity governance must operate within conformity-assured quality management systems.

8. SME ENGAGEMENT: Engage practitioners with demonstrated, long-term experience in integrated AI-cybersecurity governance systems — including the undersigned — as subject matter expert contributors through the OLIR Program.

Respectfully submitted,

A. K. (Anoop) Bungay
Principal Broker & Governor
MQCC® Bungay International (BII™), Washington, DC, USA
MQCC® MortgageQuote Canada Corp., Calgary, Alberta, Canada
www.mqcc.org · www.mqcc-ai.com · www.cyberlockchain.com

¹ Bungay, A. K. (2020). The 21st CENTURY SCIENTIFIC METHOD™: Triangle to Triangle Pyramid to Solid Square Pyramid: A Stronger Scientific Method using Trademark "Principles of 'BlockChain'™": A FATHER OF BLOCKCHAIN®ᐟ™ Series. Calgary, AB: MQCC™ Money Quality Conformity Control Organization incorporated as MortgageQuote Canada Corp.

² Bungay, A. K. (2024). MQCC® CYBERLOCKCHAIN™ brand of Federated (distributed), Quantum Generative, Hybrid Human-AI™ (QG-HHAI™) Higher Level (Meta)™ Military-Grade, Defense-Standard, Risk-based, Cybersecurity Infrastructure: A FATHER OF BLOCKCHAIN®ᐟ™ Series. Calgary, AB: MQCC™ Money Quality Conformity Control Organization incorporated as MortgageQuote Canada Corp.

BIBLIOGRAPHY

Bungay, A. K. (2020). The 21st CENTURY SCIENTIFIC METHOD™: Triangle to Triangle Pyramid to Solid Square Pyramid: A Stronger Scientific Method using Trademark "Principles of 'BlockChain'™": A FATHER OF BLOCKCHAIN®ᐟ™ Series. Calgary, AB: MQCC™ Money Quality Conformity Control Organization incorporated as MortgageQuote Canada Corp. Available at: Amazon Kindle (https://www.amazon.com/dp/B08GPB7T9X) and Google Play Books (https://play.google.com/store/books/details/Anoop_Bungay_The_21st_CENTURY_SCIENTIFIC_METHOD_Tr?id=uRL5DwAAQBAJ)

Bungay, A. K. (2024). MQCC® CYBERLOCKCHAIN™ brand of Federated (distributed), Quantum Generative, Hybrid Human-AI™ (QG-HHAI™) Higher Level (Meta)™ Military-Grade, Defense-Standard, Risk-based, Cybersecurity Infrastructure: A FATHER OF BLOCKCHAIN®ᐟ™ Series. Calgary, AB: MQCC™ Money Quality Conformity Control Organization incorporated as MortgageQuote Canada Corp. Available at: Amazon Kindle (https://www.amazon.in/CYBERLOCKCHAINTM-distributed-Military-Grade-Defense-Standard-Commercialized-ebook/dp/B0D1FPBYB8)

FROM NIST CSF 1.0 TO 3.0: THE ARC OF CORRECTION AND THE PATHWAY FORWARD

MQCC® BIT™ NIST (BITNIST™) / NIST CSF 3.0 — A Structural Proposal

A Dual-Named Architecture: BITNIST™ (MQCC® branded) and NIST CSF 3.0 (generic)

Author: A. K. (Anoop) Bungay, Principal Broker & Governor
MQCC® Bungay International (BII™), Washington, DC, USA
MQCC® MortgageQuote Canada Corp., Calgary, Alberta, Canada
Published: [INSERT DATE] at blog.mortgagequote.ca and www.cyberlockchain.com

PART 1: THE ARC — NIST CSF 1.0 TO 2.0

CSF 1.0 — February 12, 2014

Prompted by Executive Order 13636 (President Obama, February 12, 2013), NIST released Version 1.0 of the Framework for Improving Critical Infrastructure Cybersecurity on February 12, 2014.

Structure:

• 5 Functions: Identify · Protect · Detect · Respond · Recover

• 23 Categories

• 108 Subcategories

• Scope: Critical infrastructure only

• Governance: Buried as subcategory ID.GV within the IDENTIFY function — 4 subcategories. Subordinate. An afterthought.

CSF 1.1 — April 16, 2018

An incremental update. Refined identity management and access control nomenclature. Enhanced supply chain risk management guidance. Added self-assessment methodology. Governance remained subordinate within IDENTIFY.

Structure:

• 5 Functions (unchanged)

• 23 Categories (unchanged)

• 108 Subcategories (unchanged count)

• Scope: Still primarily critical infrastructure, though broader adoption was occurring organically

CSF 2.0 — February 26, 2024

The first major structural revision. A decade of feedback, two years of workshops (beginning February 2022), two public draft comment periods, and over 300 responses.

Structure:

• 6 Functions: GOVERN · Identify · Protect · Detect · Respond · Recover

• 22 Categories (down from 23)

• 106 Subcategories (down from 108)

• Scope: All organizations, all sectors, all sizes — no longer limited to critical infrastructure

• Title change: From "Framework for Improving Critical Infrastructure Cybersecurity" to "The NIST Cybersecurity Framework (CSF) 2.0"

The Critical Change: GOVERN elevated from a subordinate subcategory of IDENTIFY to the first, superordinate function — placed at the center of the framework wheel, informing all five operational functions. Six categories under GOVERN: Organizational Context (GV.OC), Risk Management Strategy (GV.RM), Roles, Responsibilities & Authorities (GV.RR), Policy (GV.PO), Oversight (GV.OV), Cybersecurity Supply Chain Risk Management (GV.SC).

The Timeline of Correction:

• 10 years from CSF 1.0 to CSF 2.0 (2014–2024)

• 4 years from CSF 1.1 to the start of the 2.0 revision process (2018–2022)

• 2 years from RFI to publication (2022–2024)

• Pattern: NIST moves in decade-scale revision cycles. If the pattern holds, CSF 3.0 would emerge between 2032 and 2034.

MQCC® submits that the structural gaps identified in this proposal should not wait a decade to be addressed.

PART 2: THE DELTA — NIST CSF 1.0 vs. MQCC® CYBERLOCKCHAIN® [MQCC® BIT™ NIST (BITNIST™)]

As of CSF 1.0 (February 2014), MQCC® had already been operating for 13 years (since 2001).

Dimension

NIST CSF 1.0 (2014)

MQCC® CYBERLOCKCHAIN® [BITNIST™] (2001–2014)

Governance

Subordinate subcategory (ID.GV) — 4 subcategories buried inside IDENTIFY

Superordinate function — governance as the foundation of all operations since 2001

Quality Management System

Not addressed

ISO 9001 certified continuously since May 9, 2008 (6 years before CSF 1.0)

Management as distinct function

Not recognized

Management recognized as co-equal function alongside Governance and Operations

Operations as distinct function

Conflated across 5 functions

Operations recognized as co-equal function, structurally separated

Scientific Method

None

AB21CSM™ — The Anoop Bungay 21st Century Scientific Method™ (Solid Square Pyramid, 6 vertices, EDUCATIVE™ as solid mass)¹

Scope

Critical infrastructure only

All organizations — governance-first architecture is sector-agnostic

AI Integration

Not addressed

Not yet operational (pre-AI era), but governance architecture was AI-ready by design

Federal Acquisition alignment

Not addressed

ISO 9001 QMS provides direct alignment to FAR Part 46 / DFARS 252.246 higher-level contract quality requirements

Cross-framework mapping

Informative references provided but not integrated

Integrated cross-mapping: ISO 9001, ISO/IEC 27001, NIST SP 800-53, Canadian federal/provincial regulatory frameworks

Workforce competency

Not structurally addressed

EDUCATIVE™ as precondition/in-condition/postcondition at every operational vertex

The gap in 2014 was total. NIST CSF 1.0 had no governance architecture, no quality management system foundation, no management/operations separation, no scientific method, no workforce competency integration, and no federal acquisition alignment. MQCC® had all of these — and had been operating them for 13 years.

PART 3: THE DELTA — NIST CSF 2.0 vs. MQCC® CYBERLOCKCHAIN® [MQCC® BIT™ NIST (BITNIST™)]

NIST corrected one gap. Five remain.

Dimension

NIST CSF 2.0 (2024)

MQCC® CYBERLOCKCHAIN® [BITNIST™] (2001–2026)

Governance

✅ CORRECTED — GOVERN elevated to superordinate function, 6 categories, center of wheel

✅ Superordinate since 2001 — 23 years before NIST

Quality Management System

❌ Still not addressed — no QMS requirement or integration pathway

✅ ISO 9001:2015 continuously certified since May 9, 2008 — governance operates within certified QMS

Management as distinct function

❌ Not recognized — management activities distributed undifferentiated across operational functions

✅ MANAGEMENT recognized as co-equal function within CIGMOS™ (Governance · Management · Operations)

Operations as distinct function

❌ Not recognized — operations conflated with the 5 operational functions

✅ OPERATIONS recognized as co-equal function, structurally separated — all market tools operate here

Scientific Method

❌ Not addressed — framework provides taxonomy (what) but no method (how)

✅ AB21CSM™ — governing scientific method supersubsumes the system; EDUCATIVE™ as solid mass at every vertex¹

Scope

✅ CORRECTED — expanded to all organizations

✅ Always sector-agnostic

AI Governance

⚠️ Mentioned — references AI RMF, discusses AI-assisted analysis in SP 1347

✅ HHAIQMS™ operational — AI substrates performing conformity assessment under documented human governance authority within certified QMS

Federal Acquisition alignment

❌ Not addressed — no connection to FAR/DFARS/CFR higher-level contract quality requirements

✅ ISO 9001 QMS provides direct alignment; CYBERLOCKCHAIN® operates at defense-standard, military-grade conformity assurance²

Cross-framework mapping

✅ IMPROVED — OLIR Program, expanded informative references

✅ Live cross-mapping in production: NIST CSF, ISO 9001, ISO/IEC 27001, SP 800-53, NICE, OSFI, PCMLTFA, provincial frameworks

Workforce competency

⚠️ Partial — NICE Framework embedded as informative reference

✅ EDUCATIVE™ — workforce competency is the solid mass of the AB21CSM™ method, not a bolted-on reference

Summary of CSF 2.0 gaps remaining:

1. No QMS integration

2. No Management/Operations separation (GMO)

3. No governing scientific method

4. No federal acquisition alignment

5. AI governance mentioned but not structurally integrated

PART 4: THE PROPOSAL — NIST CSF 3.0 SKELETAL STRUCTURE

MQCC® proposes the following skeletal structure for NIST CSF 3.0, addressing all five remaining gaps while preserving the corrections achieved in CSF 2.0.

4.1 Structural Architecture: From 6 Functions to 3 Tiers + 5 Operational Functions

TIER 1 — METHOD (Superordinate: governs the entire framework)

The framework requires a governing scientific method — a structured approach to organizational learning, knowledge codification, system creation, conformity verification, and continual improvement. Without the method, the framework is a static taxonomy.

Proposed structure:

• MT.EN — Entry into Standards-based Operating Environment

• MT.LN — Organizational Learning and Knowledge Acquisition

• MT.WR — Knowledge Codification and Constitutional Documentation

• MT.CR — System Creation and Execution

• MT.PV — Conformity Verification and Proof

• MT.IM — Continual Improvement and Feedback

EDUCATIVE — the substance of learning — operates as precondition, in-condition, and postcondition at every subcategory within every category within every function across all tiers.

TIER 2 — SYSTEM (Contains 3 co-equal functions)

The system tier replaces the single GOVERN function with three co-equal organizational functions:

• GOVERN (GV) — Direction, authority, accountability, policy, oversight
  
  

  • Retains all 6 CSF 2.0 GOVERN categories (GV.OC, GV.RM, GV.RR, GV.PO, GV.OV, GV.SC)

  • Adds: GV.QM — Quality Management System Integration

  • Adds: GV.FA — Federal Acquisition and Contract Quality Requirements Alignment

  • Adds: GV.AI — AI Governance (human authority, documented review, QMS oversight of AI outputs)

• MANAGE (MG) — Planning, resourcing, organizing, coordinating, measuring
  
  

  • MG.PL — Cybersecurity Program Planning and Resourcing

  • MG.WF — Workforce Competency Management (absorbs and elevates NICE Framework from informative reference to structural function)

  • MG.PM — Performance Measurement and Management Review

  • MG.CF — Cross-Framework Harmonization and Multi-Jurisdictional Compliance Management

  • MG.CM — Change Management and Configuration Control

• OPERATE (OP) — Execution, delivery, performance
  
  

  • OP.TL — Tool Deployment, Integration, and Lifecycle Management

  • OP.SV — Service Delivery and Operational Performance

  • OP.IN — Incident Execution (operational response and recovery actions)

  • OP.MN — Continuous Monitoring and Operational Awareness

  • OP.SC — Supply Chain Operational Execution

TIER 3 — FUNCTIONS (5 Operational Outcome Functions — retained from CSF 2.0)

• IDENTIFY (ID) — The organization's current cybersecurity risks are understood

• PROTECT (PR) — Safeguards to manage the organization's cybersecurity risks are used

• DETECT (DE) — Possible cybersecurity attacks and compromises are found and analyzed

• RESPOND (RS) — Actions regarding a detected cybersecurity incident are taken

• RECOVER (RC) — Assets and operations affected by a cybersecurity incident are restored

These 5 functions are retained as operational outcome functions. They describe what happens. Tiers 1 and 2 describe how it is governed, managed, and operated — and why it improves.

4.4 TIER 1 DETAIL — AB21CSM™: The Anoop Bungay 21st Century Scientific Method™¹

The 6 vertices of the Solid Square Pyramid are not aspirational principles. They are the structural sequence through which any organization enters, learns within, codifies, builds, verifies, and improves its cybersecurity posture. Each vertex is a functional stage:

• ENTER → Structural entry into a pre-existing Standards-based Operating Environment (CIGMOS™). The organization does not begin by learning the framework in isolation — it enters an environment where governance, management, and operations infrastructure already exists and operates. Entry is not cognitive. It is architectural.
  
  

• LEARN → Acquisition of knowledge within the environment. The organization learns the standards, the cross-mappings, the regulatory requirements, the workforce competency expectations, and the operational procedures that govern its cybersecurity program. Learning is continuous and operates within — not prior to — the system.
  
  

• WRITE → Codification of the constitution. The organization documents its policies, procedures, risk treatment plans, organizational profiles, cross-framework mappings, and quality management system documentation. What is not written does not govern.
  
  

• CREATE → Construction and execution of the system. The organization builds its cybersecurity program — deploys tools, establishes monitoring, configures controls, implements workforce training, and activates operational processes. Creation is governed by what was written. What was written is governed by what was learned. What was learned is governed by what was entered.
  
  

• PROVE → Conformity verification. The organization demonstrates — through audit, assessment, certification, testing, and documented evidence — that its cybersecurity program conforms to the standards, regulations, and organizational requirements it has adopted. Proof is not optional. Without it, governance is assertion.
  
  

• IMPROVE → Continual improvement and feedback. The organization feeds findings, nonconformities, incidents, lessons learned, and performance data back to the ENTER point — initiating the next cycle. Improvement is structural, not aspirational. It is the mechanism that prevents the framework from becoming static.
  
  

EDUCATIVE™ — the solid mass of the Solid Square Pyramid — is NOT a vertex. It is not a step, not a phase, not a function. It is the substance that fills the entire structure. EDUCATIVE™ operates simultaneously as:

• Precondition — before the action at every vertex

• In-condition — during the action at every vertex

• Postcondition — after the action at every vertex

At every vertex. Every sub-vector. Every level. Every tier.

This is why workforce competency (the NICE Framework) cannot be merely an informative reference bolted onto the framework. It is the educative mass through which every governance, management, and operations function is performed. CSF 3.0 must recognize this architecturally.

4.5 The QU-HHAI™ Tri-Phase Cascade™ — A Higher-Order System

QU-HHAI™ (Quantum-Unified Hybrid Human-AI) introduces a higher-order abstraction that defines the only valid system order for lawful operation. This ordering is not philosophical — it is structural. It separates what may exist, what may act, and what must be maintained:

Phase 1 — CONSTITUTIVE™ What may exist. The constitutional foundation. Before any cybersecurity system operates, it must be constituted — its authority established, its scope defined, its governance documented, its legal and regulatory basis confirmed. Nothing operates without constitutional authority. GOVERN (Tier 2) derives its authority from the CONSTITUTIVE™ phase.

Phase 2 — EXECUTORIAL™ What may act. The operational execution. Only after constitutional authority is established may the system execute — deploy tools, monitor threats, detect incidents, respond, recover. MANAGE and OPERATE (Tier 2) and all five operational functions (Tier 3) derive their authority to act from the CONSTITUTIVE™ phase. Execution without constitution is unlawful.

Phase 3 — GOVERNOMIC™ What must be maintained. The continuous governance of the governed. After constitution and execution, the system must be continuously governed — measured, reviewed, improved, re-constituted where necessary. GOVERNOMIC™ is the feedback mechanism that prevents governance from becoming static. It is the IMPROVE vertex of AB21CSM™ operating at system scale.

The Cascade is unidirectional and inviolable:

CONSTITUTIVE™ → EXECUTORIAL™ → GOVERNOMIC™

    (exist)          (act)          (maintain)

        ↑                              │

        └──────────────────────────────┘

              (continuous improvement)

Every cybersecurity tool on the market — CrowdStrike, Fortinet, Palo Alto, Glasswing, all of them — operates at Phase 2 (EXECUTORIAL™), within the OPERATE function (Tier 2), at the operational functions level (Tier 3). They have no Phase 1 (CONSTITUTIVE™). They have no Phase 3 (GOVERNOMIC™). They execute. That is all they do.

NIST CSF 2.0 partially addresses Phase 1 through the GOVERN function. It does not address Phase 3 as a distinct, continuous governance-of-governance mechanism. CSF 3.0 should.

4.6 The Relationship Between Tiers and Phases

QU-HHAI™ TRI-PHASE CASCADE™

    CONSTITUTIVE™ → EXECUTORIAL™ → GOVERNOMIC™

         │                │               │

         ▼                ▼               ▼

TIER 1: METHOD (AB21CSM™ — The Governing Scientific Method)

    ENTER → LEARN → WRITE → CREATE → PROVE → IMPROVE

    EDUCATIVE™ = the solid mass (precondition · in-condition · postcondition)

    │

    │   SUPERSUBSUMPTION™ — the method contains the system

    │

TIER 2: SYSTEM (CIGMOS™ — Three Co-Equal Functions)

    ├── GOVERN (GV) — direction, policy, oversight, QMS, AI governance, FAR

    ├── MANAGE (MG) — planning, workforce, measurement, cross-framework

    └── OPERATE (OP) — tools, service delivery, monitoring, execution

        │

        │   All market tools plug in at OPERATE

        │

TIER 3: FUNCTIONS (5 Operational Outcome Functions)

    ├── IDENTIFY

    ├── PROTECT

    ├── DETECT

    ├── RESPOND

    └── RECOVER

4.7 What CSF 3.0 Achieves That CSF 2.0 Does Not

Gap

CSF 2.0 Status

CSF 3.0 Resolution

QMS Integration

Not addressed

GV.QM — Quality Management System Integration as GOVERN category

GMO Separation

Only G recognized

GOVERN, MANAGE, OPERATE as 3 co-equal Tier 2 functions

Scientific Method

No method — taxonomy only

TIER 1 METHOD — 6 categories providing the mechanism for how to govern, learn, and improve

Federal Acquisition

Not addressed

GV.FA — Federal Acquisition alignment as GOVERN category

AI Governance

Mentioned, not structural

GV.AI — AI Governance as GOVERN category with human authority, QMS oversight requirements

Workforce Competency

Informative reference only

MG.WF — elevated from reference to structural MANAGE category

Cross-Framework

OLIR program (external)

MG.CF — Cross-Framework Harmonization as structural MANAGE category

Tool vs. System distinction

Implicit

Explicit — tools operate at OPERATE (Tier 2); system governs at GOVERN + MANAGE; method educates at TIER 1

Compliance vs. Tautologiconformity

Compliance model — discretionary, asserted, contingent

Tautologiconformity™ — structural, self-proving, recursively conformant; nonconformance structurally resisted and self-corrected by design

4.8 Backward Compatibility

CSF 3.0 as proposed is fully backward-compatible with CSF 2.0:

• All 6 CSF 2.0 GOVERN categories are retained within the GOVERN function

• All 5 operational functions (Identify, Protect, Detect, Respond, Recover) are retained as Tier 3

• All 106 CSF 2.0 subcategories map into the 3-tier structure without loss

• CSF 2.0 organizational profiles remain valid — they map to Tier 3

• CSF 2.0 informative references remain valid — they are absorbed into MG.CF

Organizations currently implementing CSF 2.0 can adopt CSF 3.0 incrementally by adding Tier 1 (Method) and expanding Tier 2 (from GOVERN alone to GOVERN + MANAGE + OPERATE).

PART 5: TAUTOLOGICONFORMITY™ — THE SCIENTIFIC BASIS FOR THE ARCHITECTURE

5.1 The Problem with Compliance

Every cybersecurity framework in existence — including NIST CSF 2.0 — operates on a compliance model: the framework defines outcomes, and organizations choose to implement controls that satisfy those outcomes. Compliance is discretionary. It is asserted, not proven by structure. An organization can claim compliance, pass an audit, and still suffer a catastrophic breach — because the compliance was contingent, not architectural.

This is not a failure of any particular framework. It is a failure of the compliance model itself.

5.2 The Tautologiconformity Alternative

MQCC® proposes that the destination of cybersecurity governance is not better compliance. It is tautologiconformity™ — the condition in which the output of a standards-based system is self-provingly conformant to the normative input that created it, such that conformity is true by structure rather than by assertion.

Tautologiconformity (noun): A condition within conformity science in which the output of a standards-based system is self-provingly conformant to the normative input that created it, through a recursive three-stage cycle: normative input (precondition), standards-integrated action (in-condition), and self-proving output (postcondition) — where the output becomes the normative input of the next cycle. Unlike compliance, which can be contingent, partial, or asserted without proof, tautologiconformity is structural, continuous, and architecturally inherent. The concept applies to rule-bound environments such as cybersecurity governance, quality management, finance, and artificial-intelligence systems, and describes the condition in which a system structurally resists non-conformant outcomes and self-corrects when deviations occur, because conformity is an inherent property of the architecture itself. (Coined by Anoop Bungay.)

Tautologiconformant (adjective): Describing a system, process, or architecture whose conformity to defined requirements is self-proving by structure — true by design rather than by assertion, choice, or external enforcement. A tautologiconformant system produces conformant outcomes as an inherent property of its architecture, such that nonconformance is structurally resisted, and when it occurs, is detectable, traceable, and correctable by design. A tautologiconformant architecture reduces reliance on discretionary decisions which might lead to a nonconformity event, because the conformity is embedded in the infrastructure itself — the system is the standard. (Coined by Anoop Bungay.)

5.3 The Recursive Cycle: N-I-S-T

The four letters of NIST, as understood within the BITNIST™ architecture, are not an acronym borrowed from the National Institute of Standards and Technology. They describe the operating cycle of tautologiconformity itself:

NORMATIVE (precondition) → INTERNATIONAL STANDARDS-integrated (action) → TAUTOLOGICONFORMITY (outcome = next input)

• Normative — the input. The requirement. What should be. The precondition. Before the standard exists, something is normative — an expectation, a stakeholder requirement, a regulatory demand. This is the CONSTITUTIVE™ phase. This is ENTER → LEARN → WRITE.
  
  

• International Standards-integrated — the action. The normative requirement in operation. The standard is the normative input codified, implemented, and enforced. This is the EXECUTORIAL™ phase. This is CREATE → PROVE.
  
  

• Tautologiconformity — the output. The outcome of a standards-based action is self-proving in relation to the normative input that created it. If you entered the standard, learned within it, wrote the constitution, created the system, and proved conformity — the output is tautologiconformant to the input. This is the GOVERNOMIC™ phase. This is IMPROVE — and IMPROVE feeds back to the normative input, making the next cycle's precondition itself a product of the prior cycle's tautologiconformant output.
  
  

The cycle is closed. Self-proving. Recursively conformant.

5.4 Why This Is Inevitable, Not New

Tautologiconformity is not a new way for cybersecurity. It is the inevitable way — the destination that every serious cybersecurity program is moving toward, whether it knows it or not.

The delay is not technological. It is cognitive. It takes time-in-practice for humans to understand what standards-based architecture has always made possible. NIST itself demonstrated this: it took ten years (2014–2024) to recognize that governance should be superordinate. MQCC® had operated that architecture for thirteen years before NIST published CSF 1.0.

The pattern will repeat. NIST will eventually recognize that:

• Governance requires Management and Operations as co-equal functions (GMO)

• A framework requires a governing scientific method (AB21CSM™)

• Compliance must evolve toward tautologiconformity

• Cybersecurity governance must integrate with federal acquisition quality requirements (FAR/DFARS/CFR)

• AI governance must be structurally embedded, not merely referenced

MQCC® has had twenty-five years of time-in-practice. The architecture is not ahead of its time. The world is behind the architecture.

5.5 NO THINKING REQUIRED™ — The Operational Expression of Tautologiconformity

MQCC®'s operational slogan — NO THINKING REQUIRED™ — is the colloquial expression of tautologiconformity. It does not mean "don't think." It means: in a tautologiconformant system, you do not need to think about whether you are conforming, because the system structurally resists nonconformance and self-corrects when deviations occur. The standard is the system. The system is the standard.

This slogan was operational at MQCC® before the word tautologiconformity existed. The architecture preceded the vocabulary. Twenty-five years of time-in-practice — ENTER → LEARN → WRITE → CREATE → PROVE → IMPROVE — produced the scientific term that validates what the architecture always was.

The slogan is the proof. The proof is the slogan. Tautologiconformity.

PART 6: THE RECORD

Date

Entity

Event

August 14, 2001

MQCC®

Founded. Governance-first architecture established.

April 9, 2005

MQCC®

PrivateLender.org® commercialized — governance-first peer-to-peer electronic finance.

May 9, 2008

MQCC®

ISO 9001 certification achieved. Continuously maintained to present.

February 12, 2013

USA

Executive Order 13636 — Improving Critical Infrastructure Cybersecurity.

February 12, 2014

NIST

CSF 1.0 released. Governance buried as ID.GV subcategory.

April 16, 2018

NIST

CSF 1.1 released. Governance remains subordinate.

October 2018

MQCC®

Integrated Cybersecurity Framework formalized. Governance superordinate. ISO 9001 integrated. Cross-framework mapping operational.

2020

MQCC®

AB21CSM™ textbook published.¹

February 2022

NIST

CSF 2.0 revision process begins (RFI).

February 26, 2024

NIST

CSF 2.0 released. GOVERN elevated to superordinate — 6 years after MQCC® formalized the same architecture.

2024

MQCC®

CYBERLOCKCHAIN™ textbook published.²

April 10, 2026

MQCC®

AI TRUST PANEL™ produces world's first independent, standards-based conformity assessment of a frontier AI cybersecurity initiative.

[INSERT DATE] 2026

MQCC®

Public comment submitted to NIST on SP 1347. CSF 3.0 skeletal structure proposed. BITNIST™ architecture published. Tautologiconformity™ and tautologiconformant™ coined — the scientific basis for NO THINKING REQUIRED™.

The pattern is consistent: MQCC® builds and operates the architecture. NIST eventually adopts the same structural position. The gap between MQCC® and NIST has been 6–23 years depending on the dimension measured.

This proposal offers NIST the opportunity to close that gap in the next revision cycle rather than waiting another decade.

PART 7: MQCC® BIT™ NIST (BITNIST™) — DECLARATION OF INDEPENDENT ARCHITECTURE

7.1 The Dual-Name Architecture

This proposal carries a dual (binary) name:

• MQCC® BIT™ NIST (BITNIST™) — the MQCC® branded, trademarked, complete architecture. Expanded: MQCC® Bungay International Technology (BIT™) Normative International Standards-integrated Tautologiconformity (NIST™) System-Network (www.system-network.com)

• NIST CSF 3.0 — the generic designation for whatever NIST eventually publishes as its next major framework revision

The BITNIST™ name is an homage to BITCOIN® and the BIT™ (Bungay International Technology) family of trademarks — the same family that produced BIT™, COIN™, BITCOIN®, BITMORTGAGE®, BITSENTIENT AI™, and every "BIT-" prefixed mark in the MQCC® portfolio. BITNIST™ follows the same naming logic: MQCC® BIT™ applied to the NIST cybersecurity framework domain.

7.2 The Position

MQCC® has built the complete architecture described in this proposal. It is not a concept. It is not a whitepaper exercise. It is operational, certified, and continuously maintained. It has been operational since 2001 — 13 years before NIST CSF 1.0 existed.

MQCC® will proceed as follows:

If NIST adopts the structural input contained in this proposal — the 3-tier architecture, the GMO separation, the governing scientific method, the QMS integration, the federal acquisition alignment, the AI governance framework, the QU-HHAI™ Tri-Phase Cascade™ — then BITNIST™ and NIST CSF 3.0 will be equivalent architectures. MQCC® will maintain BITNIST™ as the branded, trademarked implementation of the generic NIST standard, in the same way that any organization maintains a branded implementation of a generic international standard.

If NIST publishes a CSF 3.0 with a different structure that does not adopt MQCC®'s input, MQCC® will continue to operate, publish, and develop BITNIST™ independently as the complete cybersecurity governance architecture — the architecture that NIST CSF has been progressively converging toward since 2014, whether NIST recognizes it or not.

In either case, BITNIST™ exists. It exists now. It is published. It is trademarked. It is operational.

7.3 The BITNIST™ Versioning Doctrine

Unlike NIST CSF — which has undergone naming changes (1.0, 1.1, 2.0) and title changes ("Framework for Improving Critical Infrastructure Cybersecurity" → "The NIST Cybersecurity Framework") — BITNIST™ carries no version number in its name.

BITNIST™ is a complete whole. It is not version 1.0 of anything. It is not a draft. It is the architecture that MQCC® has been building, operating, and continuously improving since 2001.

Future updates to BITNIST™ will be version updates (e.g., BITNIST™ v2, v3), not naming updates. The architecture is complete. The name is permanent. The improvement is continuous.

This is the same doctrine that governs all MQCC® trademark brands: the name is the source identifier; the version is the state of continuous improvement. The name does not change because the identity does not change.

7.4 Notice

MQCC® hereby provides public notice of its intent to use, publish, and commercially operate the BITNIST™ trademark brand in connection with cybersecurity governance, management, and operations services.

Any party that objects to MQCC®'s use of the BITNIST™ mark — including the United States Government, the National Institute of Standards and Technology, or any other entity — is invited to raise that objection now.

MQCC® makes this invitation in the same spirit in which it has held the registered trademarks BITCOIN®, BLOCKCHAIN®, CRYPTO®, FATHER OF BITCOIN®, FATHER OF BLOCKCHAIN®, and FATHER OF CRYPTO® — marks that have stood unchallenged despite multi-trillion-dollar industries with every financial incentive to contest them. Silence from those with everything to gain is deafening proof.

Object now, or forever hold your peace.

PART 8: INVITATION

MQCC® is prepared to contribute the complete BITNIST™ / CYBERLOCKCHAIN® architectural specification — including the AB21CSM™ method, the CIGMOS™ system, the GMO separation, the QU-HHAI™ Tri-Phase Cascade™, the tautologiconformity doctrine, the QMS integration pathway, the federal acquisition alignment, and the AI governance framework — to NIST's CSF development process.

The skeletal structure proposed in Part 4 is offered as a starting point for discussion — not as a finished product. NIST's collaborative, multi-stakeholder development process is the appropriate mechanism for refining and validating this architecture.

The published doctrinal sources are available:

¹ Bungay, A. K. (2020). The 21st CENTURY SCIENTIFIC METHOD™: Triangle to Triangle Pyramid to Solid Square Pyramid: A Stronger Scientific Method using Trademark "Principles of 'BlockChain'™": A FATHER OF BLOCKCHAIN®ᐟ™ Series. Calgary, AB: MQCC™ Money Quality Conformity Control Organization incorporated as MortgageQuote Canada Corp. Available at: Amazon Kindle (https://www.amazon.com/dp/B08GPB7T9X) and Google Play Books (https://play.google.com/store/books/details/Anoop_Bungay_The_21st_CENTURY_SCIENTIFIC_METHOD_Tr?id=uRL5DwAAQBAJ)

² Bungay, A. K. (2024). MQCC® CYBERLOCKCHAIN™ brand of Federated (distributed), Quantum Generative, Hybrid Human-AI™ (QG-HHAI™) Higher Level (Meta)™ Military-Grade, Defense-Standard, Risk-based, Cybersecurity Infrastructure: A FATHER OF BLOCKCHAIN®ᐟ™ Series. Calgary, AB: MQCC™ Money Quality Conformity Control Organization incorporated as MortgageQuote Canada Corp. Available at: Amazon Kindle (https://www.amazon.in/CYBERLOCKCHAINTM-distributed-Military-Grade-Defense-Standard-Commercialized-ebook/dp/B0D1FPBYB8)

A. K. (Anoop) Bungay
Principal Broker & Governor
MQCC® Bungay International (BII™), Washington, DC, USA
MQCC® MortgageQuote Canada Corp., Calgary, Alberta, Canada
www.mqcc.org · www.mqcc-ai.com · www.cyberlockchain.com

MQCC® CYBERLOCKCHAIN®
Conformity-Yoked Bungay Enterprise Risk-based Logic Order Command Kernel
Cyber/Non-Cyber Harmonized Artificial/Non-Artificial Intelligent Network

ISO 9001:2015 Certified · Continuously Since May 9, 2008
The Higher Level (Meta) Quantum Computer Company™
PLUG 'N PERFORM™ · NO THINKING REQUIRED™

IF IT IS NOT TRACEABLE TO BUNGAY, IT IS NOT TRUSTABLE™.