Hi, am going to copy you on the penalty language and sample confirm with penalty language I sent to Matt Fleming today.
I will follow up and forward to you, a sample of a normal fully-managed confirmation.
I think the "normal" confirm could easily be duplicated.
I will also send a more complex version that I think will have to be done by Legal.
See below for penalty language info.
Thanks, Christy

Tier -- Penalty Language