4. Content of Comments

The OIR contemplates that "this proceeding will be conducted through a written record" and today we expand the process to include a workshop and oral argument. Today's order directs Respondents to participate fully and we invite all other interested persons and entities to participate as well. Our release, today, of this amendment to the OIR marks the commencement of what we hope will prove to be a candid public discussion.

Comments, filed in accordance with the schedule set forth below, should focus on the discussion of the problems and potential solutions and should (a) explain the reasons for the position advanced and (b) in the case of opposition to any proposed solution, suggest an alternative or alternatives to avoid the underlying problem. Comments should focus, in particular, upon the cost or relative burden of implementing a proposed solution and the magnitude of the harm likely if the solution is not implemented, to the extent qualification and/or quantification of the of latter can be approximated. We will consider all comments as we develop draft revisions to the Affiliates Transaction Rules and GO 77-L.