TRADE COMPLIANCE

GUIDELINES FOR

PREPARING AGREEMENTS

(Revision *.0)

Technical Assistance Agreements

Manufacturing License Agreements

And

Warehouse and Distribution Agreements

These Guidelines were prepared by the U.S. Department of State’s Bureau of Political-Military Affairs, Directorate of Defense Trade Controls, Office of Defense Trade Controls Licensing

(DTCL). They are intended to serve as an aid in applying the International Traffic in Arms Regulations (ITAR*), to provide clarity on DTCL policy as it pertains to Agreements, and to establish a standard basis for submissions of agreements and related correspondence. Should changes to the regulations take place, such regulatory changes take precedence. We welcome the use of this document in training programs but request there be no charge for the material. In instances where material is extracted, reference should be made to this publication as the source. If you have specific questions on any matter related to this guidance, contact the Office of Defense Trade Controls Licensing for further assistance. Comments or suggestions regarding this publication should be directed to this office, ATTN: Guidelines for Agreements.

* References throughout the guidelines to sections of the ITAR are denoted with either the symbol

§, or with the nomenclature “22 CFR.”

//Original Signed//

Catherine Hamilton

Director of Licensing

Directorate of Defense Trade Controls

As of: February 14, 2022

Guidelines for Preparing Agreements (Revision 5.0) 1

Revision Summary

The purpose of Revision 5.0 is to restructure the Agreement Guidelines in a more logical and orderly fashion. For this reason, the past practice of highlighting all changes in the text has not been adopted. Only changes of significance are highlighted. The majority of the text remains unchanged but has been relocated and combined with like topics in order to provide more coherent guidance. Some verbiage has been modified for grammatical reasons. Additionally, duplicative information previously requested in the transmittal letter has been deleted. Some formatting changes are also provided based on industry best practices. Applicants are not required to submit an amendment for the sole purpose of conforming an agreement to any language or format change presented in these Guidelines. Any changes presented in the Transmittal Letter or Agreement format are intended as an aid to the applicant. These changes are not mandatory. Applications that contain additional information or a different format will still be processed.

The following is a list of noteworthy changes to previous guidance:

• Under certain circumstances, cover letters are no longer required with executed copies of TAAs and WDAs (see Section 5.2.1)

• Expedited Execution is expanded to include the removal of sublicensees (see Section 13.1)

• The U.S. Sublicensing statement is no longer required (see Section 9.1)

• Optional language when utilizing § 126.18 is now provided (see Section 10.3.1)

• Clarification that the description of end-use includes the identification of platforms

(throughout Part 1)

• Clarification on identifying and documenting foreign end users (see Section 12)

• Clarification on the “deployment clause” (see Section 17)

• Update to documentation of space launch territories on the DSP-5 vehicle (see Section 18)

• Clarify that the 124.4(b) letter must provide an estimate of the quantity of the articles authorized to be produced. Additionally, MLAs involving the licensed manufacture of defense article abroad should identify the estimated quantity as part of the scope of the agreement (see Section 1.1.1, 2.1.1, and 5.2)

Since many topics from the previous version of the Agreement Guidelines are also pertinent to other types of authorizations, they have been removed from this document and are now addressed as separate guidance on the DDTC website. These topics include:

• Part 130 Statements (previously Section 3.4)

• Foreign Party GC (“Option 3”) for DN/TCN Authorizations (previously Section 3.5.3)

• Utilization of Law Firms and Consultants (previously Section 3.15)

• Authorizations Submitted in Support of U.S. Operations (previously Section 3.16)

• Certification Letter (§ 126.13) Guidance (previously Section 4)

• Guidance on Export Control Reform (previously Section 20) Guidelines for Preparing Agreements (Revision 5.0) 2

Table of Contents

Introduction 4 Part 1 Preparing an Agreement Submission 7 1 – Transmittal Letter 8 1.1 – Instructions for TAA/MLA Transmittal Letters 8 1.2 – Template for TAA/MLA Transmittal Letters 12 1.3 – Instructions for WDA Transmittal Letters 17 1.4 – Template for WDA Transmittal Letters 19 2 - Proposed Agreement 22 2.1 - Instructions for TAAs and MLAs 22 2.2 - TAA/MLA Template 25 2.3 – Instructions for WDAs 31 2.4 – WDA Template 33 3 – DSP-5 “Vehicle” 37 3.1 – General DSP-5 Vehicle Guidance 37 3.2 – Instructions for Completing the DSP-5 Vehicle 38 4 – Amendments to an Agreement 44 4.1 – Transmittal Letter 44 4.2 – Proposed Agreement 50 4.3 – Minor Amendments 51 5 – Uploading Documents to DECCS 53 5.1 – Uploading Submission Documents 53 5.2 – Uploading Post-Approval Documents 54 Part 2 Additional Guidance 57 6 – Agreement Duration and Expiration Date 58 7 – Establishing Value 59 7.1 – Components of Value 59 7.2 – The Valuation Table 61 7.3 – Agreements with MDE 63 7.4 – Agreements Utilizing Hardware Exemptions 64 Guidelines for Preparing Agreements (Revision 5.0) 3

7.5 – Decrementing Value 65 8 – Congressional Notification 66 9 – Sublicensing 69 10 – Dual and Third Country Nationals 71 10.1 – General Guidance on Dual and Third Country Nationals 71 10.2 – Requests for DDTC Vetting of Non-§ 126.1 Nationalities 72 10.3 – Requests for DDTC Vetting of § 126.1 Nationals 73 10.4 – Exemptions for Authorizing Dual and Third Country Nationals 76 11 – Contract Employees 78 12 – Foreign End Users 82 13 – Execution of an Agreement 83 13.1 – Expedited Execution 83 14 – Proviso Reconsideration 85 15 – Exporting Hardware in Furtherance of Agreements 88 15.1 – Hardware via Separate IFO Licenses 88 15.2 – Repair and Replacement Hardware 91 15.3 – Decrementing Hardware Value Authorized in Agreements 92 16 – Incremental Signing 93 16.1 – Arbitration-Related Agreements 93 16.2 – Space Insurance Agreements 96 17 – Support to Foreign Deployed Forces 98 18 – Non-Signatory Space Launch Service Providers 99 Part 3 Exceptional Cases and Exemptions 101 19 – Limited Defense Services 102 20 – Agreements Utilizing the § 123.16(b)(1) Exemption 103 Acronyms 104 Guidelines for Preparing Agreements (Revision 5.0) 4

Introduction

What is an Agreement?

An agreement approved by DTCL is the primary mechanism for authorizing a U.S. person to furnish defense services and/or disclose technical data to a foreign person, manufacture defense articles abroad, or establish a distribution point abroad for defense articles of U.S. origin for subsequent distribution to foreign persons. The scope of an agreement may encompass a range of licensable activities to include exports, reexports, retransfers and temporary imports but the furnishing of a defense service, transfer of manufacturing know-how or production rights, or the establishment of a distribution point abroad is what distinguishes an “Agreement” from other forms of authorizations issued by DTCL.

Types of Agreements

There are three types of agreements: Technical Assistance Agreements, Manufacturing License Agreements, and Warehouse and Distribution Agreements. See ITAR §§ 120.21-23 for the definition of each.

Elements of an Agreement Submission

Transmittal Letter - The Transmittal Letter serves as an explanatory letter providing an executive summary of the proposed agreement. The letter provides specific export and technical information as required by the ITAR and outlined in these guidelines and is for U.S. government use only. Agreement – The agreement is the part of the submission package that will be signed by the applicant, all U.S. signatories, and all foreign signatories, and serves as the mechanism for detailing the scope of the effort and the roles and responsibilities of each participant with regards to the USML defense articles, including technical data, and defense services. It is the only part of the submission package that the foreign signatories must see, since it requires their approval and signature.

Addendums, Attachments, and Appendices – These may include Statements of Work, Descriptions of Technical Data, Hardware for Export, Sublicensee lists, or other items referenced in the proposed agreement. These items are considered an integral part of the agreement and should be integrated with the proposed agreement into a single document when possible. DSP-5 “Vehicle” – The electronic form utilized for submitting, reviewing, and approving agreement proposals.

1

Supporting Documentation – These may include Positive Part 130 Statements, Congressional Notification documentation, Software Source Code requests, information relevant to technology 1

For the purposes of clarification, the term “DSP-5 vehicle” will be used when referring to the electronic form used to transmit the Agreement via the DECCS system. Conversely, any reference to “DSP-5” alone shall refer to the means by which an applicant may apply for a license for a permanent export, per ITAR § 123. Guidelines for Preparing Agreements (Revision 5.0) 5

export issues, precedent cases, or product brochures. This is generally material not directly referenced in the agreement but may help support the review process. This type of information should be minimized to include only information absolutely critical to the support of the request. Agreement Numbering and Tracking

For tracking purposes, agreements will be issued two independent sets of identification numbers. A nine-digit number with the “05” prefix will be generated automatically by DECCS. This is the number of record for the proposed agreement or amendment and is the number referenced throughout the adjudication process. If the applicant has a query in reference to a submitted proposal, they must reference this number.

A second number will also be assigned upon receipt. This number serves as the agreement number

(e.g., TA-9876-13) and provides a common reference for all activities that occur under the approved agreement throughout its duration. This number will be included with the nine-digit number upon final action.

General Guidance

a. It is recommended that the agreement be reviewed by the foreign licensees and other U.S. Signatories prior to submission to DTCL so that the parties can resolve problems with the language or details of the transaction.

b. In the DTCL approval, the applicant may be directed to make changes to the agreement via provisos. These changes must be made prior to executing the agreement. Therefore, it is recommended that the parties sign the agreement only after DTCL approval has been received. c. Do not reference non-U.S. laws and regulations in the agreement. DTCL Agreements are U.S. export authorizations and agreements shall not be used to enforce the laws or regulations of any other country. DTCL recommends that the applicant use the business contract or other documents between the parties if another country’s laws/regulations must be referenced for a transaction.

d. Do not include contractual business clauses in the agreement or embed an agreement into a business contract. The agreement is a U.S. export authorization and is not the appropriate vehicle for contractual business clauses.

e. Approvals are limited to the specific commodities, systems, and platforms that are specifically identified in the agreement. Citing a “family of systems” or “X-series” is insufficient. Furthermore, avoid using open-ended language in the agreement (e.g., “including but not limited to”) as this may not provide adequate authorization for commodities, systems, and platforms that were not specifically identified. Components and parts do not need to be identified down to each individual component. A representative list is sufficient. 2

2 DTCL notes that under certain circumstances, the identification of end use platforms may not be possible. Submissions will be adjudicated on a case-by-case basis. Guidelines for Preparing Agreements (Revision 5.0) 6

f. Do not use organizational collective terms (e.g., NATO, EU, AU, ESA) without defining territories for the transfer of defense articles or the furnishing of defense services. Any proposed agreement submitted to DTCL should specifically list the countries of the collective organization since membership in such collective organizations is subject to change. Once all countries are identified, the applicant may use the collective term rather than re-addressing each of the collective members. In the body of the agreement, it is recommended that the collective term be defined in one of the “Whereas” clauses. Additionally, one entry should be included on the DSP-5 vehicle for each applicable country code for the collective organization. Full address information (street/city information) only needs to be listed for the address in the primary country of the organization.

g. All transfers must occur within approved territories. Agreements may include countries other than the countries of signatories, sublicensees and end use, but those countries must be identified in the agreement. Examples include technical discussions taking place in a country outside the territory of the signatories, or the foreign licensees supporting armed forces while on deployment.

h. Freight forwarders should not be identified in agreement submissions. Freight forwarders should only be identified in licenses in furtherance of (IFO) an agreement. When utilizing the 123.16(b) exemption, see Section 20.

Guidelines for Preparing Agreements (Revision 5.0) 7

Part 1

Preparing an Agreement

Submission

Guidelines for Preparing Agreements (Revision 5.0) 8

1 – Transmittal Letter

A Transmittal Letter has the following elements:

(1) Preamble

(2) Transaction Summary

(3) Required information per § 124.12(a) or § 124.14(e)

(4) Verbatim statements as required per § 124.12(b) and § 124.14(f).

(5) Supplementary information

1.1 – Instructions for TAA/MLA Transmittal Letters a. Preamble – The preamble to the transmittal letter provides the reviewing officer with a concise description of what the package includes and the purpose (to include commodity) of the request.

b. Transaction Summary – The transaction summary should provide a brief description of the proposed agreement. If possible, keep this section to no longer than one page and include:

- A general scope of effort to include defense articles and defense services that will be provided

- Description of the roles of each party

- Names and description of the end users and end use platforms

- A short review of the commodity or program as necessary

- Information on the type of technology or data that will be transferred. Attachments can be included that contain more detailed information, but a short description is still required c. References – List previous relevant agreements (to include DSP-5 vehicle numbers), licenses, general correspondence submissions, and FMS cases if applicable. 1.1.1. § 124.12(a) Requirements

The applicant must comply with ITAR § 124.12(a), “Required Information in Letters of Transmittal.” All information required pursuant to that section must be provided. If any provision of this section is not applicable, indicate this in the transmittal letter. The requirements of § 124.12(a) are reproduced in the template in Section 1.2. Specific guidance on certain § 124.12(a) requirements follows:

a. § 124.12(a)(2). Provide a statement identifying the licensee(s) and the scope of the agreement. This section should include:

(1) Identifying Licensee(s):

(A) The name and specific addresses (P.O. Box is not sufficient) of all U.S. and foreign signatories to the agreement. Only one location is required for governmental entities. Guidelines for Preparing Agreements (Revision 5.0) 9

For private companies, the primary business location where activity will occur under the agreement should be identified. If the private company has other business locations in the same country that will be involved, either list all of those locations or add the phrase "(and all locations in [identify the country])." If the same legal entity has business locations in different countries that will participate in the agreement, at least one address per legal entity per country must be identified in order to authorize transfers to those locations.

(2) Scope of the Agreement:

(A) A brief description of the commodity or program, and tasks to be performed, to include the end user, end use and end use platform.

(i) For MLAs, the applicant must clearly differentiate between defense articles to be exported and defense articles to be manufactured abroad.

(ii) For MLAs, the applicant should provide the quantity of each defense article to be manufactured abroad.

(B) The expiration date of the agreement. For guidance on determining the expiration date, see Section 6.

b. § 124.12(a)(6). The applicant must provide a breakdown of the actual or estimated value of the agreement. See Section 7 for guidance on completing the valuation table. Do not include the value of paragraph (x)

3

commodities, software, or technology. The hardware value of the agreement must only include USML hardware, and the technical data value must only include USML technical data. The hardware manufactured abroad value for an MLA must only include the value of USML hardware manufactured abroad. Note: If the value of the agreement is $500,000 or more, an additional statement must be made regarding the payment of political contributions, fees or commissions, pursuant to Part 130 of the ITAR. This statement will be made in Block 22 of the DSP-5 vehicle. For additional guidance on Part 130 statements, see the DDTC website.

1.1.2. Statements Required by § 124.12(b)

The statements in § 124.12(b) must be included verbatim as they appear in the ITAR. 1.1.3. Supplemental Information

a. Hardware Licenses. If the agreement involves the export or temporary import of hardware, include the following statement:

“Defense articles (hardware) intended for export in furtherance of this agreement will be shipped via separate license (e.g., DSP-5, DSP-73, DSP-61, DSP-85).” 3 Paragraph (x) is found in most USML categories and allows, in certain circumstances, exporters to obtain an authorization from DTCL for the export of commodities, software, and technology controlled on the CCL. Guidelines for Preparing Agreements (Revision 5.0) 10

b. USML Categories. Identify all USML categories that relate to the agreement to the lowest USML subcategory. If the agreement proposes only the export of technical data and/or the furnishing of defense services, specify the USML hardware categories and subcategories that are related to the technical data and defense services. c. SME. Specify whether technical data and hardware are/are not designated as Significant Military Equipment (SME).

d. Gas Turbine Engine Technology. If the agreement is related to USML Category XIX, answer the following Gas Turbine Engine Technology Questions. Applicants are cautioned not to alter the wording of the questions or apply other company definitions such as “advanced technology.”

(1) Will defense services or technical data related to gas turbine engine design methodology, including any data used to establish the physical characteristics of an engine, assembly, subassembly or part be exported? If yes, explain in detail.

(2) Will defense services, hardware or technical data related to the Hot Section of the engine

(i.e. combustion chambers/liners; high pressure turbine blades, vanes, disks and related cooled structure; cooled low pressure turbine blades, vanes, disks and related cooled structure; cooled augmentor concepts; or cooled nozzle concepts) be exported? If yes, explain in detail.

(3) Will defense services or technical data related to gas turbine engine electronics controls

(e.g., Full Authority Digital Engine Controls (FADECs), Digital Electronic Engine Controls (DEECs)) be exported? If yes, explain in detail.

(4) Will engine deck models be exported? If yes, explain in detail.

(5) Will defense services or technical data related to engine survivability, vulnerability, EMI/EMV/EME, Low Observable technology, signature characteristics, performance limitations or deficiencies be exported? If yes, explain in detail. e. LO/CLO and CPI Statement. All agreement transmittal letters should address whether the contemplated exports include Low Observable/Counter-Low Observable (LO/CLO) technology and/or Critical Program Information (CPI) (see DoD Manual S-5230.28).

(1) If the answer is no, include the following statement:

"The export contemplated herein does NOT involve the discussion, offer, or release of systems, techniques, technologies, or capabilities described in DoD ManualS-5230.28 nor the discussion, offer, or release of Critical Program Information."

(2) If the answer is yes, provide a positive statement and answer the following questions.

(A) When was the sponsoring service notified of this specific license request?

(B) Did the sponsoring service recommend a LO/CLO or AT Executive Agent review? If not, attach a copy of the response.

(C) Has this specific license request been briefed to the LO/CLO Tri-Service Committee

(TSC), LO/CLO EXCOM or AT Executive Agent? If so, provide date(s). Also, provide contact info for a knowledgeable DoD point of contact (POC). Guidelines for Preparing Agreements (Revision 5.0) 11

(D) Has the LO/CLO TSC, LO/CLO EXCOM or AT Executive Agent provided formal feedback regarding the contemplated export? If so, provide date(s). Also, provide contact info for a knowledgeable DoD POC.

Note: Applicants are cautioned to answer the questions as written and only provide “yes” or “no” answers, POC, and date so that the answers remain UNCLASSIFIED. f. Congressional Notification. Provide a statement whether the proposed agreement requires Congressional Notification. For guidance on Congressional Notification, see Section 8. g. Law/Consulting Firms. If utilizing a law firm or consulting firm, provide a statement that the firm is authorized to interact with the U.S. government on the applicant’s behalf, and define what activities they are authorized to conduct (i.e., submit information, serve as a point of contact) and provide firm point of contact information. h. Signature. The transmittal letter must be signed, preferably by an empowered official. Additionally, an empowered official must sign transmittal letters when allowing law firms or consulting firms to interact with the U.S. government on behalf of the applicant. Transmittal letters may be signed using digital signatures.

Guidelines for Preparing Agreements (Revision 5.0) 12

1.2 – Template for TAA/MLA Transmittal Letters

ABC Company

1234 South Rd.

Anywhere, VA 98765

May 7, 20xx

Director

Office of Defense Trade Controls Licensing

2401 E Street N.W., Suite 1200 (SA-1)

Washington, D.C. 20522-0112

Subject: Proposed Technical Assistance Agreement (or Manufacturing License Agreement) for the support (or manufacture) of the How to Write Agreements Processor References: TA 1234-00; TA-6543-09 (050xxxxxx)

Dear Director:

Submitted herewith is a submission package which includes this letter and the proposed Technical Assistance Agreement for the transfer of certain technical information, hardware (if applicable) and services necessary for the integration, troubleshooting, and maintenance of the How to Write Agreements Processor.

TRANSACTION SUMMARY

Provide a brief description on the purpose of the agreement and how it will be executed by the parties to include scope, role of parties to include the end users, review of defense articles and services to be transferred, and any known precedent export pertaining to the agreement. REQUIRED INFORMATION

In accordance with § 124.12, the following information is provided:

(a)(1) The DDTC applicant code is M-0000.

(a)(2) The parties to this agreement are as follows: The foreign licensee(s)

XXX Technologies

Full Address (no P.O. Box)

Country

Guidelines for Preparing Agreements (Revision 5.0) 13

AAAA Systems Incorporated

Full Address (no P.O. Box)

Country

U.S. Signatories

ABC Company

1234 South Rd.

Anywhere, VA 98765

U.S. Agreement Writers Guild

Full Address (no P.O. Box)

The scope of this agreement entails (Applicant) furnishing defense services <or> providing manufacturing know-how if an MLA <or> disclosing technical data <or> providing defense articles (applicant should provide a one-line description) to the licensee(s) for the (briefly identify task to be performed) of (commodity or program) for end use by (identify end use and end user). This agreement is valid until March 31, 20XX. (Choose appropriate month per Section 6)

(a)(3) Identify relevant U.S. government contracts under which equipment or technical data was generated, improved or developed and supplied to the U.S. government (to include any relationship to any Foreign Military Sales (FMS) case), and whether the equipment or technical data was derived from any bid or other proposal to the U.S. government. If none, so state and identify cognizant U.S. military service.

(a)(4) The highest U.S. military security classification of the equipment or technical data to be transferred under the terms of this agreement is (Unclassified, Confidential, Secret or Top Secret).

(If foreign classified equipment or technical data is to be transferred, state as such, and identify whether or not the U.S. parties will generate or modify the foreign classified information).

(a)(5) State whether any patent requests which disclose any of the subject matter of the equipment or related technical data covered by an invention secrecy order issued by the U.S. Patent and Trademark Office are on file concerning this agreement. If so, list the patents herein.

(a)(6) The estimated value of this agreement is as follows: Guidelines for Preparing Agreements (Revision 5.0) 14

Line

Number

Item Value

1 Technical Data and Defense Services $1,000,000

2

3

4

5

6

Hardware

Permanent Export by DSP-5 or DSP-85 (Tooling/Support Equipment)

Permanent Export by DSP-5 or DSP-85 (Kits and Components incorporated into manufactured items) (MLA only)

Temporary Export by DSP-73 or DSP-85

Temporary Import by DSP-61 or DSP-85

Total Licensed Hardware (Sum of lines 2, 3, 4 & 5)

$21,000,000

N/A

$3,000,000

$4,000,000

$28,000,000

7 Hardware Value for Congressional Notification (line 2) $21,000,000 8 Hardware Manufactured Abroad (Line 3 plus work done by foreign licensees as result of the MLA) (MLA only) N/A

9 AGREEMENT TOTAL VALUE (Sum of lines 1, 6 & 8) $29,000,000 10 Congressional Notification Value (Sum of lines 1, 7 & 8) $22,000,000

(a)(7) Applicant must provide a statement indicating whether any foreign military sales credits or loan guarantees are or will be involved in financing the agreement.

(a)(8) The agreement must describe any classified information involved (U.S. or foreign) and identify, from DoD form DD 254, the address and telephone number of the U.S. government office that classified the information and the classification source (i.e., document). If no classified information is involved, so state, but do not omit.

(a)(9) For agreements that may require the export of classified information, the Defense Security Service cognizant security offices that have responsibility for the facilities of the U.S. parties to the agreement shall be identified. The facility security clearance codes of the U.S. parties shall also be provided. If no classified information is involved, so state, but do not omit.

REQUIRED STATEMENTS

(b)(1) If the agreement is approved by the Department of State, such approval will not be construed by (the applicant) as passing on the legality of the agreement from the standpoint of antitrust laws or other applicable statutes, nor will (the applicant) construe the Department's approval as constituting either approval or disapproval of any of the business terms or conditions between the parties to the agreement.

NOTE: If the agreement involves the export of MDE, see Section 7.3 for additional guidance on preparing the valuation table.

NOTE: The following statements must be included verbatim from ITAR § 124.12(b). Guidelines for Preparing Agreements (Revision 5.0) 15

(b)(2) The (applicant) will not permit the proposed agreement to enter into force until it has been approved by the Department of State.

(b)(3) The (applicant) will furnish the Department of State with one copy of the signed agreement

(or amendment) within 30 days from the date that the agreement is concluded and will inform the Department of its termination not less than 30 days prior to the expiration and provide information on the continuation of any foreign rights or the flow of technical data to the foreign party. If a decision is made not to conclude the proposed agreement, the applicant will so inform the Department within 60 days.

(b)(4) If this agreement grants any rights to sub-license, it will be amended to require that all sub- licensing arrangements incorporate all the provisions of the base agreement that refer to the U.S. government and the Department of State (i.e., 22 CFR 124.8 and 124.9). SUPPLEMENTAL INFORMATION:

Defense articles intended for export in furtherance of this agreement will be shipped via separate license (e.g., DSP-5. DSP-73, etc.). <or> No defense articles (hardware) will be shipped in furtherance of this agreement. Only technical data and/or other defense services will be provided. This agreement relates to the following U.S. Munitions List category(ies): (e.g., XII(c)(2)(i

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