ESP Question

David:
Mark and I were reviewing the Eligible Swap Participant rules and the
following issue came up:

If our counterparty is a limited partnership but our credit group is relying
on the credit of the GP, do the rules require a written guaranty from the GP
or is it enough to rely on the fact that under law the GP is jointly and
severally liable for the LP's obligations? One of our counterparties is a
limited partnership whose GP is a utility and their counsel has advised us
that for regulatory reasons, the GP cannot enter into a Guaranty. I look
forward to hearing from you.
Carol