the Federal Register. Northwest Airlines Comments: Commenters expressed a concern that the contribution of Pinnacle Stock involves a conflict of interest on the part of Northwest. Future contributions of Pinnacle Stock will continue to be subject to independent review and valuation. Finally, the Department notes that the Independent Fiduciary's satisfaction of its obligations in connection with the determination of the fair market value of the Pinnacle Stock as previously described by the Department in the Preamble to the final exemption is a critical factor in the Department's decision to grant a final exemption. Northwest observed that the comments submitted to the Department raised several concerns regarding the contribution of Pinnacle Stock to the Plans, as contemplated by the Proposed Exemption. As previously mentioned in the March 3 Comment, the changes to the description of the Put Option in the Proposed Exemption are noted by the Independent Fiduciary who adds that the Proposed Exemption should be revised in accordance with the definition of Market Value in section 1.1 and the language of section 8.3 of the Omnibus Agreement. The amount of the Initial Contribution is equal to the amount that was required to meet the quarterly funding requirements under ERISA section 302 and Code section 412(l) for the Contract Plan due on January 15, 2003. Pursuant to the terms of the Omnibus Agreement, Northwest contributed Pinnacle Stock to the Contract Plan. Many of the commenters expressed concern about the effect of the Proposed Exemption on the Plans. Except for one director appointed by Northwest, Pinnacle's board is independent of Northwest. Employee Fiduciary Counselors, AIC and Eclat represent that the ASA between Northwest and Pinnacle provided the framework for the final valuation. District 143 members at This is because a cash contribution is not a viable alternative given the company's liquidity needs. (j) That the fair market value of the stock has been determined by way of a prudent investigation. HW]I }g$*+iQF.3K`>63A; FQN\C t~Yr~XXm-~8?w?/Tfu"]K^u**]HY~^Ne8U*Zb[,kSYj/kKXRUl*0koD{]n RpuPX+k0yJbtp2mt8q`p}`/n2+eT_wq)7z4Ee e2v EUv`Z6x8uq7 {]f;v.