I appreciate the point. I think the point is very well taken, that the current paragraph (a) specifically says that guidelines and interpretation notes are issued for information purposes only and are not binding on those listed registered parties. It is important that Scott's point be known, that this is making binding on the external auditor something not being binding as such on others.
For the reasons I gave, the purpose is to create part of an enforcement structure that the external auditors play a role in. That's why it would be justified as an exception, the same way as the commissioner is actually effectively bound by these. This is why the commissioner needs to have more of an organic connection to the process of generating these things, which partly goes back to Tom's amendment that was already adopted.
It's not an attempt to make an end run around this; it's recognizing what we think is a difference.