ITSR GL D-1 and 560.540 — Scenario Matrix, Associated Comment

Date issued: Nov. 30 2019

Last substantive commentary amendment:
May. 20 2024

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (530 words)

[5-20-24 update - this chart has been rendered largely obsolete by the issuance of GL D-2 and subsequent incorporation of GL D-2 into 560.540. See comments to 560.540] The Comments below have not been amended to reflect this fact].

---

ITSR GL D-1 and 560.540 — Scenario Matrix, Associated Comment:


The native file associated with this document (avail. upon request) is an excel table, identifying the scope of ITSR GL D-1 and 560.540 in the context of dozens of differing factual scenarios. Note that is has not been updated in light of the issuance of Iran GL D-2, but the changes to GL D would not appear to disturb the analyses found on the spreadsheet to a significant degree.

The scope and interconnectedness of these GLs is extremely complex. As is evident from the Matrix, there are many significant variables that go into...