Note: Generally, only one (1) OD is required for the SCA but DSS may require additional one in situations of an increased security concern. SSAs/PAs/VTAs generally require three (3) ODs/PHs/Trustees. In the case of the SSA, the number of ODs must exceed the number of Inside Directors (IDs). The PA and the VTA do not allow foreign representation on the cleared company's board. If the company will be requesting less than three (3) ODs/PHs/Trustees, a letter should be provided to DSS with a justification or rationale as to why the company believes that less than three (3) ODs/PHs/Trustees can implement the requirements the requirements of the agreement.
Additional information and a template Affiliated Operations Plan can be found here.
Note: Additional documents may be required to complete the process of implementing a FOCI mitigation instrument.