Comment Text:
Sack Consulting serves as adviser to the Market Practices Committee of the Association of Institutional INVESTORS. The comments of the Association regarding ICE Clear Credit LLC's Request for Exemptive Relief, dated October 4, 2011 and relating to single customer accounts for positions in single name CDS and broad-based credit indices, are included in the attached comment letter from Steven Chittenden of Loomis Sayles & Company, L.P. who serves as Chair of the Committee.