What OpenAI's policy paper establishes institutionally is a template where compliance cost becomes competitive moat [3]. Strict frontier model regulation sounds neutral — it applies to everyone equally — but equal rules produce unequal outcomes when the regulated parties differ in scale. OpenAI, with its legal team, lobbying relationships, and existing safety infrastructure, absorbs those costs. A smaller lab building a competing foundation model does not. The governance architecture OpenAI is advocating is precisely the kind that incumbents design and challengers inherit.