Q3-7 & Q3-5d get to the workability. I don't think OpenAI responds to that part of the RFC. Meta's comment on that issue seems to be fairly clear, they oppose the proposed rules on KYC for IaaS and are "not aware of technical capabilities that could not be overcome by determined, well-resourced, and capable actors".
https://www.ntia.gov/sites/default/files/publications/open_m...
https://about.fb.com/wp-content/uploads/2024/03/NTIA-RFC-Met...