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Information Technology Industry Council, ITI Recommendations to the Department of Homeland Security Regarding its Work Developing a Voluntary Program Under Executive Order 13636, "Improving Critical Infrastructure Cybersecurity" (Feb. 11, 2014) (full-text).
ITI released a set of recommendations eying further improvement of the framework, changes that call for DHS to "de-emphasize the current focus on incentives." Partly, ITI recognizes the cyber order can produce change even in an environment in which fiscal constraints and congressional inaction stall incenties for adoption — but a bigger business argument is that ITI and others do not want incentives if they come at the cost of "compliance-based programs."