On June 10, 2013, the European Securities and Markets Authority (“ESMA”), following a request from the European Commission, published a report comparing the liability regimes applied by member states (“Member States”) of the European Economic Area (“EEA”) in relation to the Prospectus Directive (Directive 2003/71/EC as amended by Directive 2010/73/EU). The Prospectus Directive provides the overarching European regulatory framework for the publication of prospectuses in connection with debt and equity securities being offered to the public or admitted to trading on regulated markets in the EEA.

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