Financial Services Authority November 7, 2011 The FSA has fined Coutts Company (" Coutts") £6.3 million for failings in connection with the sale of the AIG Enhanced Variable Rate Fund. Coutts has also agreed to carry out a past business review, overseen by an independent third party in relation to all customers who remained invested at 15 September 2008 and will compensate all customers who have suffered a loss as a result of its failings.

Consilium November 8, 2011 The Council of the European Union has adopted a directive amending the financial conglomerate directive (" FICOD") in order to close loopholes and ensure appropriate supplementary supervision of financial entities in a financial conglomerate. The new directive also adapts the supervision of financial conglomerates to the EU's new supervisory structure. The revision of FICOD also amends the relevant legislation on banking and insurance supervision, namely the capital requirements directive (2006/48/EC and 2006/49/EC) and the directive on supplementary supervision of

European Parliament November 15, 2011 The European Parliament has adopted a proposal for a regulation on short selling and credit default swaps. Key points of the proposal include restrictions on entering into naked CDS whose underlying relates to sovereign debt, recordkeeping requirements for holders of significant net short positions, and the obligation to report net short positions constituting to 0.5% or more of an issuer's issued share capital The resolution will now be considered by the Council of Ministers.

November 15, 2011 The European Commission has published proposals to reform the EU Regulation on Credit Rating Agencies in an effort to create greater transparency and competition amongst credit rating agencies operating in the EU. Measures proposed include (i) more transparent and timely sovereign ratings, (ii) decreasing investors' reliance on ratings through avenues such as greater access to information from issuers (iii) increased diversity and independence of credit rating agencies, and (iv) avenues for investors to seek redress against credit rating agencies. The proposals will now pass

November 21, 2011 The European Securities and Markets Authority has published the most recent statements from national regulators on measures to control the use of short selling in their respective jurisdictions.