The 7-field spec is applied at class level for routine cognition and at artifact level only for load-bearing cognition. Classifying a piece of cognition as routine versus load-bearing is itself a deferral of the 7-field review. Holder and reviewer of that classification are unspecified. Sierra Club's operative drafts sat in the draft class the triage would leave at rule level.

The Scottish WhatsApp success column is a device ban, not owned deferral of cognition that still exists. Channel closure removes a formation path. The page already says holder and corrective owner of the replacement regime depend on internal arrangements not established by the ban. The specimen that closed the failure does not instantiate the primitive.

The Reviewer field requires power to order upward movement of cognition across a formation threshold. Existing second-order reviewers (Scottish Information Commissioner, General Court in Pfizergate) can order disclosure or reconsideration of possession of artifacts that already exist. They cannot order unrecorded cognition to become a record. The page's own post-ban Reviewer slot is filled with a disclosure commissioner.

Exemption 5 already supplies a conversion criterion: legal finality and agency treatment as settled policy, not practical influence. Sierra Club applies that criterion and rejects operative-effect. The remainder is not a missing conversion test; it is which 7-field criterion would overrule legal finality while the draft is still not legally final. Without that criterion, owned conversion relitigates the case.

The ATRS/PLP gap is a coverage failure of a system-level public metadata standard. Recoding a missing register entry as Record Gate treats non-publication of a system card as the same failure as holding load-bearing cognition below file, after the page split disclosure from formation.

EO 14303 moves Exemption 5 invocation for a defined class to the agency head with written authorization and OSTP notice. The agency head is the incumbent whose interest the legitimacy claim says defaults to keeping cognition out of admissibility. OSTP notice is not power to order upward movement against the head.

Section VII lists EU AI Act Articles 12/13/26/86, UK ATRS, France's individual notice, Canada's AIA, the Dutch register, Australia's ART, and CK as one Record Gate domain. These sit at different chain steps. The page already says they are often separate thresholds with different owners, then treats the list as one gate. No row except CK is compiled through the 7 fields.

The legitimacy biconditional treats unowned holding as fake non-recording / incumbent-interest discretion. Section II already lists volume, fragmented IT, inherited filing, and resource shortage as causes that do not require bad faith. A named office that cannot process the volume is overflow, not a missing costume. Unowned and overwhelmed get the same verdict.