From what I had learned a while back, I'm pretty sure that GEAR had removed themselves from that equation a long time ago. I'll try to make some phone calls to ask some more questions about such.
That Section 3(a)(10) Exemption was a nightmare for understanding and I must thank you and Cassandra for posing certain questions that helped to educate me on that issue. That was a new experience for me with that over there and quite a few lessons learned.