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12/13/11 9:37 AM

#219057 RE: yangside #219053

Nist xxx-147,

a concern of mine is section 3.2 being mired in should rather than shall.

Folks that implement gov regs literally scan these things for the word "shall".

Its not a deal breaker by any means. It provides for considerable wiggle room in rate of adoption however. Believe me, that is what the words are there for (in this case should). Shalls are immediate targets, shoulds are longer term targets. Shoulds evolve, they become shalls, but I can't hang my hat on 10m seats going on 2012 based on shoulds.