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Perhaps the most significant mitigating control is that in commercial fisheries transactions, both parties to the transaction (typically the fisher and the fish processor) are permitted entities and each has some responsibility for accurate and complete record-keeping and reporting (for example, the fisher may be is required to keep a logbook showing fishing efforts and catch, while the processor is required to report fish purchased). In these transactions it is typical for the parties to the transactions to have opposite and balancing interests (for example, when a fisher is selling fish to a processor, the fisher wants the amount paid to be high, while the processor wants the amount paid to be low). These multiple sources of information and counter-balanced incentives tend to make deception more difficult to initiate and sustain.

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Lowest Assurance Level that Mitigates All Impact Categories

Mitigating Controls

Appropriate Assurance Level with Consideration of Mitigating Controls

Proposed E-signature Alternative

Level 3---...appropriate for transactions needing high confidence in the asserted identity's accuracy. People may use Level 3 credentials to access restricted web services without the need for additional identity assertion controls.

Multiple sources of information, some with counter-balancing incentives.
Vessels
Buyers reporting are permitted and have an ongoing "trusted relationship" with NMFS.

E-reporting systems will detect failure to report more quickly, resulting in more responsive enforcement and potentially a higher rate of compliance.

E-reporting and e-signature can result in more immediate feedback for detectable errors, and more immediate feedback facilitates more accurate reporting.

Level 2---On balance, confidence exists that the asserted identity is accurate. Level 2 credentials are appropriate for a wide range of business with the public where agencies require an initial identity assertion (the details of which are verified independently prior to any Federal action).

NPS-like