Tom Harkin: “Yes, that is correct. We certainly understand that many special entities have internal managers that may meet the…”

“Yes, that is correct. We certainly understand that many special entities have internal managers that may meet the independent representative requirement. For example, many public electric and gas systems have employees whose job is to handle the day-to-day hedging operations of the system, and we intended to allow them to continue to rely on those in-house managers to evaluate and approve swap and security-based swap transactions, provided that the manager remained independent of the swap dealer or the security-based swap dealer and met the other conditions of the provision. Similarly, the named fiduciary or in-house asset manager--INHAM--for a pension plan may continue to approve swap and security-based swap transactions.”