Mr. Stephen Groarke:

In terms of the types of errors that we have seen, which is most of the cases that I have described, this is the first one that is a regulatory error as opposed to a legal error. The remainder of the 1,979 cases appear to be operational errors where we made a mistake in how we ran the account.

We do not believe it is a legal error, but we have certainly not fulfilled our obligations to our customers and, under the regulations, not applied the due care and diligence we should have.