-197-                                         
          of midmarket values with or without adjustment.  The July 30,               
          1993, survey reveals that (1) 49 percent of the respondents                 
          thereto used midmarket values for valuation and (2) of the                  
          respondents thereto that used midmarket values with adjustments,            
          44 percent of them adjusted for credit and 54 percent adjusted              
          for administrative costs.  The March 1994 survey reveals that (1)           
          31 percent of the respondents thereto still used midmarket values           
          without adjustments a year after the publication of the G-30                
          report and (2) of the respondents thereto using midmarket values            
          with adjustment, 32 percent adjusted for credit and 24 percent              
          adjusted for administrative costs.                                          
               Nor does the G-30 report contain a specific standard as to             
          the precise manner in which credit adjustments to midmarket                 
          values must be computed.  To the extent that the G-30 report sets           
          out general guidelines (e.g., recommendations as to netting,                
          dynamic computation of credit risk, expected versus maximum                 
          exposure), FNBC’s methodology conflicts with each of these                  
          guidelines.  In fact, FNBC’s failure to take netting into account           
          deviated in significant respects from the industry’s consensus on           
          that subject.  The CFTC viewed rationing via procedures such as             
          netting as widespread throughout the industry, and Duffie noted             
          that market participants placed significant emphasis on the use             
          of netting agreements.  Duffie also concluded that the distorting           
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