Attached is a comment letter from BITS and the Financial Services Roundtable in favor of the "special circumstances model". John Carlson Executive Director, BITS 1001 Pennsylvania Avenue, NW Suite 500 South Washington, D.C. 20004 (202) 589-2442 (office) (301) 908.1141 (cell) e-mail: john@xxxxxxxxxxx <mailto:john@xxxxxxxxxxx> www.bitsinfo.org <http://www.bitsinfo.org/> "This e-mail is intended solely for the addressee(s) and may be legally privileged and/or confidential. If you are not the intended recipient, be aware that any disclosure, copying, distribution, forwarding or use of the contents of this email, including any information in attachments, is prohibited. Additionally, if you are not an intended addressee, please delete this email and attachments and all copies from your system, destroy any hard copies and immediately notify the sender by telephone (202.289.4322) or by email. Any unauthorized retention, use or disclosure of this email and/or attachments may be unlawful. Thank you."