Financial Services Authority The Financial Services Authority has published a consultation on large exposure regimes in order to (i) propose rule changes to the FSA Handbook definition of Connected Counterparties and the basis for aggregating exposures to Connected Counterparties when applying large exposure limits, (ii) propose new guidance on the treatment of large exposures to structured finance vehicles and (ii) propose a change to the Handbook guidance on the institutional exemption. Responses on the proposals should be submitted to the FSA no later than 26 April 2012.

Financial Services Authority January 20, 2012 The FSA has issued a new policy statement on custody liens in an effort to further strengthen its client assets regime. Firms must ensure that any custody agreement they enter into on or after 1 April 2012 complies with these rules and that any custody agreement entered into before this date complies with the rules no later than 30 September 2012.

Financial Services Authority January 23, 2012 The FSA has published a discussion paper which sets out its provisional approach to implementing the Alternative Investment Fund Managers Directive in the UK. In particular, the paper touches on alternatives for policy development and identifies challenges and possible deviations for affected stakeholders. Feedback on the discussion paper should be submitted to the FSA no later than 23 March 2012.

Financial Services Authority January 27, 2012 The FSA has fined Alexander Ten-Holter, a former compliance officer at Greenlight Capital (UK) LLP, and Casper Agnew, a trading desk director at J.P. Morgan Cazenove, for actions arising from the sale of Greenlight's holdings in Punch Taverns plc. In June 2009, Ten-Holter received an order to sell Greenlight's entire shareholding in Punch, but failed to ensure that the order was not based on inside information despite being aware of facts which indicated a strong risk that it was. Agnew executed the order and was deemed to have failed to act with

Financial Services Authority January 25, 2012 David Einhorn, owner of US hedge fund Greenlight Capital Inc., has been fined along with his fund for engaging in market abuse following the fund's sale of its equity in Punch Taverns Plc. In June 2009, Einhorn participated in a telephone conference where he was alerted that Punch was at an advanced stage of the process towards a significant equity fundraising. Einhorn immediately ordered Greenlight to reduce its holding in punch by 4.5%. When the fundraising was subsequently announced, the price of Punch shares fell by 30%, a move that would have