APPENDICES

Appendix A Externship Proposal Application

Appendix B On-Site Externship Supervisor Agreement

Appendix C Externship Educational Planning Form

Appendix D Student Extern Daily Log/Timesheet

Appendix E Evaluation Forms

Appendix F Guidelines for On-Site Externship Supervisors

Appendix G ABA Standard 305

Appendix H Requirements for Externships with Private Sector For-Profit Employers

Under the Fair Labor Standards Act
 APPENDIX A

UNIVERSITY OF NEBRASKA COLLEGE OF LAW

EXTERNSHIP PROPOSAL APPLICATION

Name:__________________________________________ Date:_______________________

Class Year (Circle One) 2d Year 3d Year

Externship Proposal for: Q Fall Q Spring Q Summer __________ Year

Number of credit hours for Externship: _________________

Describe the Proposed Externship:

State how the Externship will contribute to your educational experience. Please describe the
duties or activities that you expect to perform as an extern.
What are the starting and ending dates for the Externship?

Start date: ________________________________

End date: ________________________________

Who will be the on-site supervisor for your externship?

Name of On-Site Externship Supervisor: ____________________________________________

Contact Information: ___________________________________________________________

Has the on-site externship supervisor received a copy of the Externship Program Policy
(including all Appendices)? Q Yes Q No

Does the on-site externship supervisor have a Juris Doctorate degree? Q Yes Q No

If no, additional documentation may be required to demonstrate that the proposed externship
complies with the educational goals and requirements of the Externship Program Policy.

Is the externship at a private sector for-profit employer? Q Yes Q No

If yes, please attach a separate statement signed by the individual who will be your on-site
externship supervisor explaining how the externship will comply with the requirements of the
federal Fair Labor Standards Act. Consult Appendix H of the Externship Program Policy for
further information.

I know that I need to register for these Externship hours (Law 792) in MyRED. Q Yes Q No
(Registration number can be found in the Registration Materials for the appropriate semester.)

Please attach the completed On-Site Externship Supervisor Agreement with your
Externship Proposal Application.

Required Signatures:

_____________________________________________________
Student

___________________________________________________
On-Site Externship Supervisor

_____________________________________________________
Faculty Supervisor

_____________________________________________________
Assistant Dean Date
 APPENDIX B

UNIVERSITY OF NEBRASKA COLLEGE OF LAW

ON-SITE EXTERNSHIP SUPERVISOR AGREEMENT

Name of Student Extern: _________________________________________________________

Semester and Academic Year: ___________________ Credit Hours: _____________________

Name of On-Site Externship Supervisor: ____________________________________________

Externship Placement: __________________________________________________________

Office Address:_________________________________________________________________

Telephone & E-Mail Address: ____________________________________________________

Name of Faculty Supervisor: ______________________________________________________

Telephone & E-Mail Address: _____________________________________________________

Please review and sign below:

As the On-Site Externship Supervisor for the Student Extern, I acknowledge and
agree as follows:

1. I have reviewed the University of Nebraska College of Law Externship Program Policy
(including the Appendices) and agree to comply with the educational goals and
administrative requirements stated therein.

2. I understand that the purpose of the Externship Program is to allow the student to develop his
or her professional legal skills in an applied setting.

3. I agree that the student will be given assignments that are consistent with the educational
goals of the Externship Program. Student assignments will be as challenging as the student
can reasonably handle. The student will be given feedback on assignments at regular
intervals during the semester.

4. I acknowledge that the required working time for the student will be 42.5 hours for each hour
of externship academic credit for which the student has registered.

________________________________________ ________________________
Signature of On-Site Externship Supervisor Date
 APPENDIX C

UNIVERSITY OF NEBRASKA COLLEGE OF LAW

EXTERNSHIP EDUCATIONAL PLANNING FORM

Student Name: _____________________________________________________________

Name of On-Site Externship Supervisor: _________________________________________

Telephone and E-Mail Addresses: ______________________________________________

Externship Placement: ________________________________________________________

Name of Faculty Supervisor: __________________________________________________

Telephone and E-mail Addresses: _______________________________________________

Semester and Academic Year: ____________ Credit Hours: _________________________

The purpose of this form is to assist the student and the on-site externship supervisor in the
discussion and formulation on of mutual educational goals for the semester and to think about
mechanisms for achieving those goals. Please review and complete this form together at the
commencement of the externship and return it to the faculty supervisor. As part of completing
this form, the on-site externship supervisor should explain the policy and practices
regarding client confidentiality that may apply to the student’s work during the externship.
Your signatures acknowledge that this discussion has taken place. This form must be completed
and returned to the faculty supervisor no later than one week after the starting date for the
externship listed on the original Externship Proposal Application for this field placement.

1. Please describe briefly the student’s three primary educational goals to be derived from this
externship experience.

Goal 1: ___________________________________________________________________

__________________________________________________________________________

__________________________________________________________________________

Goal 2: ____________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________
 Goal 3: ____________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

2. Please describe possible mechanisms to achieve the student’s educational goals.

Goal 1: ____________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

Goal 2: ____________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

Goal 3: ____________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________

___________________________________________________________________________
3. (To be completed by the student extern) Please describe your present areas of strength and
weakness in legal skills (e.g., research skills, writing, issue identification, reasoning, oral
advocacy, interpersonal skills, etc.). What skills would you like to improve during your
externship?

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

Signature of Student Extern: ___________________________________________________

Signature of Externship Supervisor: ______________________________________________

Externship Starting Date: ______________________________________________________

Date of Discussion: ___________________

Date Received by Faculty Supervisor: _______________________

 APPENDIX D
STUDENT EXTERN DAILY LOG/TIMESHEET

Please complete and send this timesheet to your faculty supervisor. Suggested descriptions of
externship activities are listed below. Please maintain client confidentiality as required by
the policy and practices of your externship placement in completing this log.

STUDENT NAME: DATES: _____________ to ______________

EXTERNSHIP PLACEMENT

Date Number of Hrs. Description of Work Performed (Please type or write legibly)
Mon.

Tues.

Wed.

Thurs.

Fri.

Suggested Descriptions of Externship Activities:

• Document review • Assessment/evaluation by (specify) • Meeting with (specify)

• Research • Participate in negotiation/mediation • Telephone conference with (specify)
• Draft • Observe negotiation/mediation • Participate in court/administrative
• Revise • Fact investigation and case proceeding (specify)
• Correspondence/e-mail with development • Observe court/administrative
(specify) proceeding
• Discussion with (specify)

________________________________________________________
Signature of Supervisor
 APPENDIX E

ON-SITE EXTERNSHIP SUPERVISOR’S EVALUATION OF EXTERN

Name of Student Extern

Name of On-Site Externship
Supervisor
Externship Placement
Supervisor Telephone & Email
Semester and Year
Date of Evaluation

Assessment Categories
Exemplary (Practice Ready) Competent Developing

Excellent work for a law Proficient work for a law Work needs additional content
student – on a job, the student student – on a job, the student or skills to be competent – on
could perform well with would need some input from a a job, the work would not be
minimal supervision. supervising attorney before helpful and a supervising
the student was ready to attorney would need to start
As applied to the represent clients. over or fix mistakes.
professionalism component of
this evaluation, the student As applied to the
acted in a manner that professionalism component of
comports with the level of this evaluation, the student
professionalism you would acted in a manner that you
expect of an attorney working would expect of a law student
in your office. but would need to increase the
level of professionalism if
working as an attorney.
Name of Student

Research and Analysis N/A Exemplary Competent Developing

Legal Research Skills:

found correct sources; stated
relevant law from appropriate
authorities.
Legal Analytical Ability:
correctly identified and analyzed
legal issues based upon relevant law
and policy; made appropriate
comparisons and distinctions to the
case at hand based upon the
applicable law and policy.
Problem Solving Skills:
identified the relevant facts and
issues and explored all potentially
viable options given the facts,
issues, and law.
Transactional Drafting:
drafted agreements carefully, used
proper word choice, and edited to
ensure that agreements accurately
reflected the parties understandings.
Factual Research Skills:
identified and used the appropriate
factual research skills.
Organization of Written Work:
clearly and logically organized and
easy to follow.
Writing Style:
used clear, concise, active language
and had few if any grammatical
errors or typos.
 Name of Student

Oral Presentation N/A Exemplary Competent Developing

Use of Law and Facts:

used the relevant facts and law and made
reasonable inferences and, where
applicable, clearly explained the law and
how it applied to the problem/case.

Organization:
examination or presentation was
structured logically, easy to follow, and
had clear transitions.

Wording:
used the active voice and persuasive
language; avoided legalese; when
examining witnesses, had appropriate use
of leading and non-leading questions.

Handling of questions:
answered questions with ease; elaborated
and explained when answering all
questions.

Delivery:
tone, pacing, physical gestures, and voice
modulation contributed to the
presentation.
 Name of Student

Professionalism and Ethics N/A Exemplary Competent Developing

Ethical Knowledge and Behavior:

identified and analyzed ethical issues
and informed supervisor of such;
observed client confidentiality and
other ethical rules.

Office Demeanor:
followed office procedures; kept
regular and dependable hours; was
punctual; acted in a professional
manner while at the externship site.

Time Management:
met deadlines; managed time
effectively.

Interaction with Others:

interacted effectively and respectfully
with lawyers, clients, staff, adversaries,
and other.

Learning from experience:

asked appropriate questions; learned
from feedback, critique, observations,
and experience; reflected critically and
honestly about own performance.
Name of Student: __________________________________________________

For any area in which you marked “developing” as your assessment, please briefly explain.

Did the student produce any work that you felt was particularly superior of inferior? Please
briefly explain.

What do you consider to be this student’s strengths?

What do you consider to be something this student should be working to improve?

 STUDENT EXTERN’S EVALUATION OF
ON-SITE EXTERNSHIP SUPERVISOR FORM

Name of Student Extern

Name of On-Site Externship
Supervisor
Externship Placement
Name of Faculty Supervisor
Semester and Year
Date of Evaluation

Evaluation of On-Site Externship Supervisor

Exceeded Met Did Not Meet
Quality of Site Experience Expectations Expectations Expectations
Quality of Assignments Given
Total Number of Hours Expected
Level of Supervision
Helpfulness of Supervisor
Accessibility of Supervisor
Promptness of Feedback
Usefulness of Feedback
Supervisor as Role Model
For each place you marked “did not meet expectations” or “not beneficial,” please briefly
explain:

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

Was there anything about the externship you felt was particularly superior or inferior? Please
briefly explain:

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________
How can this externship be improved for future externs (workload, supervision, other)?

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

Additional comments:

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________________________________________

________________________________________ _____________________________
Signature of Student Extern Dated Received by Faculty Supervisor
 APPENDIX F

GUIDELINES FOR EXTERNSHIP SUPERVISORS

The primary focus of the Externship Program is educational. The educational goals for the
student extern include:

1. Furthering the development of research, writing and drafting skills

2. Exploring lawyering skills related to different areas of the legal profession
3. Enhancing oral advocacy and/or communication skills
4. Developing an understanding of professional responsibility
5. Reflecting upon the role of the lawyer in a particular area of the law, and more broadly,
as related to societal issues

Confidentiality and Pre-Externship Educational Planning

Although your role as an externship supervisor will involve supervising the performance
of legal tasks, your student extern can learn other invaluable insights from your observations
about the legal system and the role of lawyers in that system. Your extern may have little or no
prior legal work experience. We require student externs to reflect on a number of issues such as:
(1) the relationships between attorneys and support staff, clients, other attorneys, judges,
legislators, and members of the public; (2) work environment and outside pressures; (3) the
relationship between the legal work and an attorney’s personal goals and values; and (4) the
ethical issues that may arise in the attorney’s particular area.

We would like your student extern to discuss these observations with you. As a mentor
to your student extern, you can add an enriching perspective to the student’s observations by
sharing your opinions about the legal system and the role of an attorney in your particular area.
In addition to requiring a daily log of work activities, we require your student extern to reflect on
the externship experiences in a written journal. The process of journal writing complements the
process of reflection.

The journal entries will be reviewed by your extern’s faculty supervisor, and it is
therefore essential for you and your student extern to have a discussion at the beginning of the
externship regarding your office’s policies and procedures governing confidentiality for the
written journal entries. This discussion regarding confidentiality rules should take place when
you and your student extern complete the Externship Educational Planning Form..

Becoming a Member of the Legal Profession

As an externship supervisor, you provide students a wealth of opportunities to not only

develop professional legal skills, but to experience and reflect upon the process of becoming a
member of the legal profession. Part of becoming a professional is learning how a particular
workplace functions. You and your extern should initially discuss:
 • The function and structure of the agency, office, or organization
• The nature of the legal work and extern’s role
• Relevant office policies and the chain of command
• Best methods for communication and scheduling meetings with you
• The student’s normal work schedule (days and hours)
• Layout of the office and library and introduction to office personnel
• The student’s workspace
• An explanation of the student’s first assignment

Suggestions for Planning and Presenting Student Assignments

A key to a successful externship is the ability of the externship supervisor to give

assignments to the extern effectively. When any project is assigned, it is important for the
student to know exactly what you expect and to communicate clearly all aspects of these
expectations. Please remember that your student extern may have little or no prior work
experience in a professional office. Listed below are some checklist-type questions that you may
find helpful in planning and presenting work assignments to your student extern.

1. Structure and explain the assignment with the relative inexperience of the
student in mind.
• Give the assignment in writing whenever possible. This gives the student something to
refer to after your assignment meeting.
• Discuss the basic objectives of the assignment or project with the student, including how
many issues you expect the student to address. Explain how this particular assignment
fits into the overall case or matter and how the assignment will accomplish your
objectives.
• Provide the student with some guidance in terms of starting points for legal research to
help focus the issue.
• Specify how you want the student’s work product, including, how technically perfect you
want the letter/memo/brief to be in terms of case citations, for example, and whether you
want a rough draft, more polished draft and/or finished product.
• Specify how much time you expect the student to spend on the assignment, including
time for research and drafting (keeping in mind that students are often inexperienced and
require extra time for thorough research).
• Specify relevant due dates for drafts and the final product and how you want the student
to check in with you for progress meetings. Make sure you and the student have
communicated your schedules to each other so that progress meetings are accomplished
as planned
• Make sure the student is aware of the format you require. If possible, provide the student
with an example of the format of the memo, brief, letter etc., to assist the student in
understanding your expectations.
• Tell the student who to ask for ask for assistance if you are unavailable.
• Ask the student if he or she has questions (again, remembering that some students may be
unfamiliar with the substantive area of law you are asking them to address).
 2. Follow up regularly as the assignment progresses.

As students begin working on assignments, they often need additional and periodic help,
assignment clarification, reassurance, or relief. Redefinition of the task is common as the student
gathers information and gains a more precise understanding of the assignment. Given that
interactions during this phase are frequently marked by informality and brevity, the importance
of these exchanges can be easily overlooked. It is important for you and the student to keep to
your scheduled progress meetings.

3. Provide feedback to the student on the completed assignment.

At the completion of an assignment, you should solicit student impressions about

performance and convey your impressions about the performance on the assignment. Without
periodic feedback, neither you nor the student extern can effectively evaluate his or her
performance and make any necessary changes to result in a final product which closely
resembles your goals for the assignment and provides your student with a sense of
accomplishment. It may be helpful during these feedback sessions to periodically review the
goals and methods listed on the completed Externship Educational Planning Form and to revise
those goals and methods as necessary.
 APPENDIX G

ABA STANDARD 305

ABA Standard 305. STUDY OUTSIDE THE CLASSROOM

(a) A law school may grant credit toward the J.D. degree for courses or a program that
permits or requires student participation in studies or activities away from or outside the
law school or in a format that does not involve attendance at regularly scheduled class
sessions.

(b) Credit granted shall be commensurate with the time and effort required and the
anticipated quality of the educational experience of the student.

(c) Each student’s academic achievement shall be evaluated by a faculty member. For
purposes of Standard 305 and its Interpretations, the term “faculty member” means a
member of the full-time or part-time faculty. When appropriate a school may use faculty
members from other law schools to supervise or assist in the supervision or review of a field
placement program.

(d) The studies or activities shall be approved in advance and periodically reviewed
following the school’s established procedures for approval of the curriculum.

(e) A field placement program shall include:

(1) a clear statement of the goals and methods, and a demonstrated relationship
between those goals and methods to the program in operation;

(2) adequate instructional resources, including faculty teaching in and supervising

the program who devote the requisite time and attention to satisfy program goals
and are sufficiently available to students;

(3) a clearly articulated method of evaluating each student’s academic performance

involving both a faculty member and the field placement supervisor;

(4) a method for selecting, training, evaluating, and communicating with field
placement supervisors;

(5) periodic on-site visits or their equivalent by a faculty member if the field
placement program awards four or more academic credits (or equivalent) for field
work in any academic term or if on-site visits or their equivalent are otherwise
necessary and appropriate;

(6) a requirement that students have successfully completed one academic year of
study prior to participation in the field placement program;
 (7) opportunities for student reflection on their field placement experience, through
a seminar, regularly scheduled tutorials, or other means of guided reflection. Where
a student can earn four or more academic credits (or equivalent) in the program for
fieldwork, the seminar, tutorial, or other means of guided reflection must be
provided contemporaneously.

Interpretation 305-1
Activities covered by Standard 305(a) include field placement, moot court, law review, and
directed research programs or courses for which credit toward the J.D. degree is granted, as
well as courses taken in parts of the college or university outside the law school for which credit
toward the J.D. degree is granted.

Interpretation 305-2
The nature of field placement programs presents special opportunities and unique challenges for
the maintenance of educational quality. Field placement programs accordingly require
particular attention from the law school and the Accreditation Committee.

Interpretation 305-3
A law school may not grant credit to a student for participation in a field placement program for
which the student receives compensation. This Interpretation does not preclude reimbursement
of reasonable out-of-pocket expenses related to the field placement.

Interpretation 305-4
(a) A law school that has a field placement program shall develop, publish and communicate to
students and field instructors a statement that describes the educational objectives of the
program.
(b) In a field placement program, as the number of students involved or the number of credits
awarded increases, the level of instructional resources devoted to the program should also
increase.

Interpretation 305-5
Standard 305 by its own force does not allow credit for Distance Education courses.
 APPENDIX H

REQUIREMENTS FOR EXTERNSHIPS WITH PRIVATE SECTOR FOR-PROFIT

EMPLOYERS UNDER THE FAIR LABOR STANDARDS ACT

The United States Department of Labor has published a fact sheet providing general
information concerning the potential application of the Fair Labor Standards Act to unpaid
externships with private sector for-profit employers. This fact sheet is reproduced below for the
convenience of employers who are considering an externship for students at the University of
Nebraska College of Law.

Wage and Hour Division (WHD)

(April 10)
Fact Sheet #71: Internship
Programs Under The Fair Labor
Standards Act.

This fact sheet provides general information to help determine whether interns must be paid the
minimum wage and overtime under the Fair Labor Standards Act for the services that they
provide to “for-profit” private sector employers.

Background

The Fair Labor Standards Act (FLSA) defines the term “employ” very broadly as including to
“suffer or permit to work.” Covered and non-exempt individuals who are “suffered or
permitted” to work must be compensated under the law for the services they perform for an
employer. Internships in the “for-profit” private sector will most often be viewed as
employment, unless the test described below relating to trainees is met. Interns in the “for-
profit” private sector who qualify as employees rather than trainees typically must be paid at
least the minimum wage and overtime compensation for hours worked over forty in a
workweek. *

The Test For Unpaid Interns

There are some circumstances under which individuals who participate in “for-profit” private
sector internships or training programs may do so without compensation. The Supreme Court
has held that the term “suffer or permit to work” cannot be interpreted so as to make a person
whose work serves only his or her own interest an employee of another who provides aid or
*
The FLSA makes a special exception under certain circumstances for individuals who volunteer to perform
services for a state or local government agency and for individuals who volunteer for humanitarian purposes for
private non-profit food banks. WHD also recognizes an exception for individuals who volunteer their time, freely
and without anticipation of compensation for religious, charitable, civic, or humanitarian purposes to non-profit
organizations. Unpaid internships i the public sector and for non-profit charitable organizations, where the intern
volunteers without expectation of compensation, are generally permissible. WHD is reviewing the need for
additional guidance on internships in the public and non-profit sectors.
instruction. This may apply to interns who receive training for their own educational benefit if
the training meets certain criteria. The determination of whether an internship or training
program meets this exclusion depends upon all of the facts and circumstances of each such
program.

The following six criteria must be applied when making this determination:

1. The internship, even though it includes actual operation of the facilities of the employer, is
similar to training which would be given in an educational environment;

2. The internship experience is for the benefit of the intern;

3. The intern does not displace regular employees, but works under close supervision of
existing staff;

4. The employer that provides the training derives no immediate advantage from the activities
of the intern; and on occasion its operations may actually be impeded;

5. The intern is not necessarily entitled to a job at the conclusion of the internship; and

6. The employer and the intern understand that the intern is not entitled to wages for the time
spent in the internship.

If all of the factors listed above are met, an employment relationship does not exist under the
FLSA, and the Act’s minimum wage and overtime provisions do not apply to the intern. This
exclusion from the definition of employment is necessarily quite narrow because the FLSA’s
definition of “employ” is very broad. Some of the most commonly discussed factors for “for-
profit” private sector internship programs are considered below.

Similar To An Education Environment And The Primary Beneficiary Of the Activity

In general, the more an internship program is structured around a classroom or academic

experience as opposed to the employer’s actual operations, the more likely the internship will be
viewed as an extension of the individual’s educational experience (this often occurs where a
college or university exercises oversight over the internship program and provides educational
credit). The more the internship provides the individual with skills that can be used in multiple
employment settings, as opposed to skills particular to one employer’s operations, the more
likely the intern would be viewed as receiving training. Under these circumstances the intern
does not perform the routine work of the business on a regular and recurring basis, and the
business is not dependent upon the work of the intern. On the other hand, if the interns are
engaged in the operations of the employer or are performing productive work (for example,
filing, performing other clerical work, or assisting customers), then the fact that they may be
receiving some benefits in the form of a new skill or improved work habits will not exclude them
from the FLSA’s minimum wage and overtime requirements because the employer benefits from
the interns’ work.
Displacement And Supervision Issues

If an employer uses interns as substitutes for regular workers or to augment its existing
workforce during specific time periods, these interns should be paid at least the minimum wage
and overtime compensation for hours worked over forty in a workweek. If the employer would
have hired additional employees or required existing staff to work additional hours had the
interns not performed the work, then the interns will be viewed as employees and entitled
compensation under the FLSA. Conversely, if the employer is providing job shadowing
opportunities that allow an intern to learn certain functions under the close and constant
supervision of regular employees, but the intern performs no or minimal work, the activity is
more likely to be viewed as a bona fide education experience. On the other hand, if the intern
receives the same level of supervision as the employer’s regular workforce, this would suggest
an employment relationship, rather than training.

Job Entitlement

The internship should be of a fixed duration, established prior to the outset of the internship.
Further, unpaid internships generally should not be used by the employer as a trial period for
individuals seeking employment as the conclusion of the internship period. If an intern is placed
with the employer for a trial period with the expectation that he or she will then be hired on a
permanent basis, that individual generally would be considered an employee under the FLSA

Where to Obtain Additional Information

This publication is for general information and is not to be considered in the same light as
official statements of position contained in the regulations.