External Meetings: Meeting with Russell Investments

The external attendees further discussed the views expressed in the February 18 comment letter.  The external attendees also discussed industry practices with respect to the following: (1) conflicts of interest disclosures (2) scenario analyses; (3) daily mark; (4) Special Entity definition and collective investment vehicles; (5) timing of certain disclosures such as term sheets; (6) recommendations; (7) policies and procedures for selecting an investment manager; (8) “independence” of Special Entity  representative; and (9) front-running prohibition.