I don't think anyone has mentioned IEACMDxx as another source of Starts, etc. 
IBM discourages user modification, probably part of why COMMDSxx exists.
And, not this isn't where the RACF address space is started.

> -----Original Message-----
> From: IBM Mainframe Discussion List <IBM-MAIN@LISTSERV.UA.EDU> On
> Behalf Of Tony Harminc
> Sent: Tuesday, May 21, 2019 11:24 AM
> To: IBM-MAIN@LISTSERV.UA.EDU
> Subject: Re: IPL process - understanding IEFSSNxx
> 
> On Tue, 21 May 2019 at 12:11, Tony Thigpen <t...@vse2pdf.com> wrote:
> 
> >
> > One of the questions I am trying to answer is "who is starting RACF
> > during IPL". It's not in COMMNDxx.
> >
> 
> Just in passing (and I realize this isn't what you're asking, but is maybe a
> terminology/concepts issue), the RACF subsystem is not RACF. That is, the
> large majority of RACF code runs in its callers' address spaces. In a way 
> it's like
> the traditional xSAM access methods. Indeed the RACF subsystem was until
> fairly recently completely optional.
> 
> Tony H.
> 
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