So Rick B,

do you have enough info to draft a set of rules for submission based on all our banter and suggestions ?

I think there is a solid piece there to get a draft around for review prior to submission... The sooner it gets infront of the committee then MA the bettererer...

Bottom line is it may not make it into the regs till 2015 so that the appropriates can get a say...so for most of us, we will more than likely be in the appropriate corresponding grades by then, but the newcomers will still benefit.