Comment on FR Doc # E6-17848

Document ID: DOD-2006-OS-0039-0002
Document Type: Public Submission
Agency: Department Of Defense
Received Date: November 03 2006, at 05:41 PM Eastern Standard Time
Date Posted: November 7 2006, at 12:00 AM Eastern Standard Time
Comment Start Date: October 25 2006, at 12:00 AM Eastern Standard Time
Comment Due Date: December 26 2006, at 11:59 PM Eastern Standard Time
Tracking Number: 801dd61e
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This proposal would appear to make it very easy for DoD to decline approval of purchase of ML/CCL items by individuals as individuals would have no way of demonstrating that they have any of the safeguards in place which would be required by the proposed rule change (financial ability to safeguard ML/CCL items, etc.). I'd like to see treatment of individual purchasers addressed more thoroughly by the proposed requirements. Will DoD be looking at individuals' credit reports? While this might be cogent in protecting ML/CCL items from improper sale to foreign entities, it should not be a deal-stopper; many of us buy items from DRMO auctions because they are cheaper than buying the same items from commercial suppliers. Individuals' credit issues, if they are to be evaluated, should not be a de facto basis for DoD to deny individuals' applications for EUCs. Also, I'd like to see some provision for appeal by individual purchasers if their application for an End User Certificate is denied. Overall, however, with regard to business enterprises who buy ML/CCL items for the express purpose of reselling them at a profit, the proposed rule change is good - I think closer scrutiny of such businesses is called for and overdue given the overall world situation.

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