Folks,

Attached is a short note for your consideration in reference to the three questions under consideration. The last paragraph of this two page note says:

The emphasis on determining whether a registrant is a natural person or a legal person is just one part of the overall data access model. It makes a qualitative difference whether or not there is shared confidence in the forthcoming existence of an effective, efficient and timely differentiated access system.

No matter where this WG sets the bar regarding distinguishing between legal and natural persons, it is vital to move forward with differentiated access. Further, this WG should say so and its decisions should be in the context of confidence that differentiated access will be part of the overall system.

This approach will not obviate the need for distinguishing legal vs natural persons, but it will relieve us of seeing this distinction as the only policy issue related to who will have access to which data.

Thanks,

Steve