Comment by David Koehler

A large frontier developer shall write, implement, comply with, and clearly and conspicuously publish on its website a frontier AI framework that applies to the large frontier developer's frontier models and describes how the large frontier developer approaches all of the following: [...] (2) defining and assessing thresholds used by the large frontier developer to identify and assess whether a frontier model has capabilities that could pose a catastrophic risk, which may include multiple-tiered thresholds; [...] (4) reviewing assessments and adequacy of mitigations as part of the decision to deploy a frontier model or use it extensively internally; [...] (10) assessing and managing catastrophic risk resulting from the internal use of its frontier models, including risks resulting from a frontier model circumventing oversight mechanisms.