Also, in many cases, source and destination service providers for a data transfer are direct competitors. Chances are they are less frank with each other about what they do than they would be with a 3rd-party organization.... which also could contractually require, as part of the certification program, that it be informed of major changes etc.

So @DTinitiative, that's all just a thought, I'm sure you have thought about all of this, so I wouldn't be surprised if there were another report soon!