• 4 pages
• For Official Use
• February 4, 2010

1. This paper addresses questions from the Chairman’s letter of December 2, 2009. For a more detailed discussion of the structure of the U.S. banking industry, see the U.S. Submission to the February 2009 Roundtable on Competition and Financial Markets, DAF/COMP/WD(2009)11.

Competition and Concentration: General Issues

How is competition in the financial sector measured in your jurisdiction? Please refer to the applicable decisions or competition guidelines of the relevant authorities in your jurisdiction.

2. In the United States, the federal antitrust laws generally apply to commercial banking and investment banking products and services in the same manner as to other economic sectors. Similarly, the Horizontal Merger Guidelines1 (Guidelines) of the U.S. Department of Justice (Department) and the U.S.
Federal Trade Commission apply to the analysis of mergers across sectors. Premerger notifications relating to non-bank mergers in the financial sector are filed pursuant to the Hart-Scott-Rodino Act and are analyzed under the Guidelines. For the review of bank mergers, special procedures have been
implemented. These policies are outlined in a document, “Bank Merger Competitive Review,” which is implemented jointly by the Department and the bank regulatory agencies. In the implementation of these policies, the Department applies the principles of the Guidelines and screens for bank merger transactions that would result in market concentration that exceeds the Herfindahl-Hirschman Index thresholds, thereby requiring further review.

Are the standard structural measures of competition (market shares, Herfindahl index, etc.) suitable to
measure concentration in the financial sector in your jurisdiction? If not, why?

3. The standard structural measures of concentration are sufficiently flexible to measure concentration in the financial sector in the United States. Calculating market shares and concentration, however, is only the first step in analyzing whether concentration will create or enhance the exercise of market power. With regard to banking, these measures specifically have been adopted by two of the bank regulatory agencies, as discussed in the “Bank Merger Competitive Review” document. Indeed, studies by the Federal Reserve Board staff have found that less concentrated local banking markets perform better in competition terms than more concentrated markets.5 The joint adoption of these guidelines was necessary, as the bank regulatory agencies and the Department share jurisdiction for competitive review of bank mergers and concurrently analyze the potential competitive effects of such mergers. While the Department applies Section 7 of the Clayton Act, the bank agencies, in addition to considering potential competitive effects, must consider the “financial and managerial resources and future prospects of the existing and proposed institutions, and the convenience and needs of the community to be served.”

In your jurisdiction, is competition in the banking sector measured differently than in other industries?

4. As discussed above, the federal antitrust laws and the Guidelines apply to mergers in the financial sector in the same manner as those in other industries.

How concentrated and how competitive was the banking system in your jurisdiction before the crisis? Can you refer to cases (e.g. mergers) where your agency had to review the degree of competition in the banking sector?

5. Despite the current financial situation, more than 7,000 separately insured banking entities and more than 12,000 credit unions currently operate in the United States, and most product and urban
geographic markets remain relatively unconcentrated. Most recently, in 2008, the Department reviewed the proposed acquisition of National City Corporation by PNC Financial Services; after review, the
Department and the Federal Reserve Board required divestitures to eliminate the anticompetitive effects that otherwise would have resulted from consummation of the acquisition. Investment banking markets are more concentrated but, as a general matter, these markets have been competitive.

Has your jurisdiction experienced a process of consolidation in the last decade before the crisis? If consolidation took place, please explain the reasons behind this process.

6. During the period 1994 through 2006, the Department reviewed more than 1,000 bank acquisition/merger applications annually. Changes to federal statutes in 1994, allowing for interstate expansion/branching and allowing bank holding companies to engage in a wider range of activities closely relating to banking, affected the number of such transactions. Additionally, in 1999, the Gramm-Leach-Bliley Act allowed for a new entity, a financial holding company, to affiliate bank holding companies, banks, insurance companies, securities firms, and other financial institutions under common ownership.

What policies were implemented to facilitate/hinder the consolidation process, if any?

7. As explained above, the enactment of certain statutes greatly expanded the geographic areas and the scope of activities within which financial sector companies could compete. Along with these came new
restrictions, as the relaxation of geographic entry barriers was accompanied by a national deposit cap of 10 percent for any one bank and a default state deposit cap of 30 percent, with the option for any state to impose its own less restrictive deposit cap. Attendant upon these statutes was an overall approach of less regulation or self-regulation, as evidenced by the 1999 Gramm-Leach-Bliley Act13 repeal of the restrictions separating commercial banking and investment banking that had been codified in the Glass-Steagall Act of 1933.

How did the consolidation process, if any, affect the degree and nature of competition among financial firms in your jurisdiction?

8. Based on the Department’s antitrust review of proposed acquisitions and actions taken to remedy the potential competitive effects of such acquisitions, competition among U.S. financial firms remains
robust.

Competition, Concentration & Crisis

Have banks or financial institutions merged as a consequence of the crisis? If yes, what was the analysis of your agency on the relation between concentration and competition? Was this analysis in any way different because of the particular situation created by the systemic crisis?

9. The financial crisis resulted in some mergers of U.S. financial institutions, as less stable firms were acquired by those that were better prepared to withstand the crisis. In analyzing the potential effects
of such acquisitions, the Department applied the same antitrust principles and analytical framework that it applies in every merger review. One example is the expedited review of the acquisition by PNC of the financially distressed National City Corporation, in which the Department required significant divestitures to eliminate any anticompetitive effects.

10. The bank merger statutes provide procedures for even more expedited competitive review of certain bank mergers, i.e., “emergency” transactions and transactions involving a bank that is a “probable
failure.” In the case of an “emergency” transaction, the bank merger statutes limit both the time in which the Department must advise the bank regulatory agency of the competitive factors relating to the
transaction and the post-approval waiting period during which the transaction may not be consummated. The Department has reviewed all of these mergers, and they have raised few competitive concerns. In the case of a “probable failure,” the bank regulatory agency may act immediately, without a competitive effects report from the Department; in such a case, the transaction may be consummated immediately upon approval by the bank regulatory agency.

• 12 pages
• For Official Use
• February 12, 2010

1. Substance and process in government antitrust investigations go hand in hand. Regardless of the outcome of an investigation, concerns about process create the impression that substantive results are flawed, whereas a fair, predictable, and transparent process bolsters the legitimacy of the enforcement outcome.

2. This submission provides an overview of the practices of the Antitrust Division of the U.S. Department of Justice (“DOJ”) and the Federal Trade Commission (“FTC”) (together, “the Agencies”) with regard to transparency and procedural fairness. Part I discusses transparency with respect to substantive standards and agency policies and procedures. Part II discusses open and frequent dialogue with the parties, and Part III addresses the closely related issue of informing parties of the allegations against them in a timely manner. Parts IV and V describe the opportunities that parties are given to respond to agency concerns and to be heard prior to an adverse decision. Part VI addresses the length of antitrust investigations, and Part VII summarizes the Agencies’ practice with regard to the publication of decisions.

3. Although the Agencies’ investigatory processes are similar, their enforcement processes differ procedurally. DOJ is a cabinet department of the U.S. government, and must initiate an enforcement action in an appropriate U.S. district court. The court determines whether the law has been violated and
orders any relief or remedy required. The FTC is an independent agency that enforces competition and consumer protection laws and may use its own administrative processes, codified in Part III of its rules, to enforce the law. Under this process, the Commission, following a full investigation, issues an
administrative complaint, which initiates an enforcement proceeding that is overseen and resolved by an administrative law judge, subject to review by the full Commission and, ultimately, a U.S. court of appeals. The FTC thus exercises both prosecutorial and judicial, functions. The FTC may seek a preliminary injunction in U.S. district court in aid of the administrative proceeding, e.g., to block a merger before it is consummated. The Commission’s process affords respondents procedural rights that are quite similar to those in a court proceeding. Thus, even though the Agencies’ processes differ, both agencies provide procedural fairness to subjects of enforcement proceedings.

1. Transparency of substantive standards and agency policies and procedures

4. There are three primary antitrust statutes in the United States: the Sherman Act, which became law in 1890; the Clayton Act, which was enacted in 1914; and the Federal Trade Commission Act, which
also became law in 1914. Under the United States common-law system, independent courts issue decisions that apply the general statutory provisions to specific facts as presented through adversarial
litigation. As the United States Supreme Court has explained:

Congress . . . did not intend the text of the Sherman Act to delineate the full meaning of the
statute or its application in concrete situations. The legislative history makes it perfectly clear
that it expected the courts to give shape to the statute’s broad mandate by drawing on commonlaw
tradition.

5. The extensive body of court decisions under the common-law system is an important way that substantive legal standards become known and transparent to the business community, lawyers,
economists, and consumers.7 In addition, the FTC, through its administrative enforcement process, contributes to the body of decisional law interpreting the Clayton and FTC Acts.

• James K. Jackson, Specialist in International Trade and Finance
• 18 pages
• March 11, 2010

Since the 1990s, the Organization for Economic Cooperation and Development (OECD) has pursued the issues of bribery and tax havens, resulting in changes to certain U.S. laws. In addition, the OECD, under the direction of its member countries, spearheaded an international agreement to outlaw crimes of bribery, and it continues to coordinate efforts aimed at reducing the occurrence of money laundering, corruption, and tax havens. Also, the OECD is a pivotal player in promoting corporate codes of conduct that attempt to develop a set of standards for multinational firms that can be applied across national borders. On May 4, 2009, President Obama outlined his Administration’s policy to “crack down on illegal tax evasion” and to close loopholes. In the 111th Congress, companion legislation was introduced in the House (H.R. 1265) and the Senate (S. 506) to restrict the use of tax havens. Some estimates indicate that tax havens cost the United States $100 billion each year in lost tax revenues (The Christian Science Monitor, Tax Havens in U.S. Cross Hairs, by David R. Francis, June 9, 2008).

…

Two high-profile cases focused attention on the use of tax havens. The first case involved an
investigation in 2008 in Germany involving 600-700 German citizens reportedly funneling funds
into banks in Liechtenstein, taking advantage of Liechtenstein-based trusts to evade paying taxes
in Germany. At that time, Andorra, the Principality of Liechtenstein, and the Principality of
Monaco were the last remaining jurisdictions listed by the OECD as uncooperative tax havens. In
May 2009, however, the OECD’s Committee on Fiscal Affairs removed all three jurisdictions
from the list as a result of commitments they each made to implement the OECD standards of
transparency and effective exchange of information and the timetable they each set for
implementation.

The second case involves the Union Bank of Switzerland (UBS). For more than a year, the IRS
had pressured the Swiss banking firm to release the names of 52,000 Americans the agency
believes have offshore accounts in Switzerland and are using Switzerland’s banking secrecy laws
to avoid paying taxes. So far, UBS has agreed to pay $780 million in fines and has admitted that it
set up shell companies and accounts in Switzerland on behalf of U.S. citizens, that it advised U.S.
citizens on the best way to hide their assets from the IRS, and that UBS employees gave U.S.
clients tips on placing pricey art and jewelry in safety deposit boxes without declaring them to the
IRS.

…

• Committee on the Safety of Nuclear Installations
• 15 pages
• For Official Use
• September 2009

1. WGAMA Mandate

Scope

The Working Group on the Analysis and Management of Accidents (WGAMA) shall be responsible for activities related to potential accidental situations in nuclear power plants, including the following technical areas: reactor coolant system thermal-hydraulics; design-basis accident including ECCS strainer clogging; pre-core melt conditions and progression of accident and in-vessel phenomena; coolability of over-heated cores; ex-vessel corium interaction with concrete and coolant; incontainment combustible gas control; physical-chemical behaviour of radioactive species in the containment; fire safety. The activities will mainly focus on existing reactors, but will also comprise applications for some advanced reactor designs. Priority setting will be based on established CSNI criteria as documented in the CSNI Operating Plan, in particular on safety significance as well as risk and uncertainty considerations.

Objective

The WGAMA objective is to assess and where necessary strengthen the technical basis needed for the
prevention, mitigation and management of potential accidents in nuclear power plants, and to
facilitate international convergence on safety issues and accident management analyses and strategies.

In order to fulfil this objective, the working group shall:

• Exchange technical experience and information relevant for resolving current or emerging safety issues
• Promote the development of phenomena-based models and codes used for the safety analysis, including the performance of benchmarking exercises
• Assess the state of knowledge in areas relevant for the accident analysis and where needed
• Promote research activities aimed to improve such understanding, while supporting the maintenance of expertise and infrastructure in nuclear safety research

The Working Group shall report to the Committee on the Safety of Nuclear Installations (CSNI) and
assist this Committee with its work. The activities will normally be carried out by small task groups,
each set up for performing a specific task under the WGAMA supervision. The output of the Working
Group will consist of state-of-the-art reports and other technical reports, workshops and related
proceedings, benchmarking exercises and joint research proposals.

The Working Group will aim to provide answers as requested by CSNI and/or CNRA and will coordinate
its work with other working groups, notably with WGRISK for risk related issues and for
priority setting, WGOE for emerging issues and WGIAGE for ageing and structure integrity
evaluation. WGAMA will also work in co-ordination with the NEA-NSC on scientific issues such as
advanced coupled neutronic / thermal-hydraulic methods. Interaction with joint projects will be
strengthened as recommended in the CSNI Operating Plan.

2. WGAMA vision and goals

The Group vision is to make significant contributions in the followings safety related areas:

• Regulatory decision-making regarding prevention and management of accidents and related high priority safety issues, through the elaboration of existing information or data available in member countries. Where appropriate, missing information should be identified, providing also recommendations on how to obtain it. The input for activities in this sector is expected to come from CSNI, CNRA (through CSNI) or directly from member countries (through their representative in WGAMA). Typically, the duration of each activity should not exceed 1-1½ year. The products would be recommendations on best use of existing knowledge for accident management purposes or on means to acquire more information where needed. Regulators and industry are to be the main users of these WGAMA products.

• Analyses of relevant operational events, for the purpose of producing an as clear as possible understanding of specific events and for identifying possible preventing measures. The analyses may expand over a broader range of conditions in order to evaluate the extent to which similar events in different circumstances might challenge plant safety. Investigations may also address industry initiatives aimed to increase plant output through e.g. power up-ratings and plant life extension, for which co-operation with other CSNI WGs would be needed. Possible lack of knowledge of the processes involved or limitations in models or computer codes prediction capability might surface from work in this sector. Thus, activities in this area may have varying duration depending on scope and on the obtained results, and may be structured in distinct self-contained phases. Input is expected to come from WGOE, from CSNI or directly from member countries. The product would be assessments based on analyses carried out by one or more parties with one or more analytical tools. Users would be regulators, safety research organisations and industry.

• Assessment of the state of knowledge and progress in the understanding of phenomena and processes governing the occurrence, progression and mitigation of potential accidents, including improved methodology 1 and performance and use of safety analysis codes. Gradually increasing attention should be given to new or advanced reactor systems, for which there will be a need of substantial knowledge build-up. As this is a broad and not precisely defined area of work, rigorous criteria should be applied in setting priorities, focusing on those areas that have higher safety relevance and/or a more pronounced risk profile, and for which relevant outcome is likely to be produced in a reasonable time frame. The activities in this sector are expected to constitute the “base-load” of the WGAMA group. As they may be long lasting, it is very important that they be well prioritised and structured, such that useful intermediate results are systematically bought forward: interaction with WGRISK is important for priority setting. Input is expected to come from CSNI or from member countries (through their representative in WGAMA and/or in WGRISK). Output is to be used by safety analysts.

Strategy for new WGAMA activities

Most of the present WGAMA programme has dealt or deals with

• Calculation tools and methods, such as the CFD and BEMUSE tasks
• Benchmarking exercises such as ISP-41, ISP-47, ISP-49, ISP-50 and CFD benchmark based on customised T-junction experiment or the accident progression exercise
• Knowledge assessment through state of the art reports, e.g. on iodine or nuclear aerosols
• Data preservation and knowledge transfer (CCVM and THICKET)

It can be observed that in most cases the programme has been oriented towards generic aspects, without entering into the specifics of well-defined issues or of particular reactor designs or accident management features. An exception has been the SERENA programme, which has focussed on the invessel and vessel steam explosion issue.

…

• 24 pages
• For Official Use
• November 30, 2009

Executive Summary

1. The Turkish Competition Authority (TCA) experienced a period of time during which global economic crisis began to impact the Turkish economy directly in 2008. The Turkish economy felt the crisis significantly in particular in the last quarter of 2008.

2. In terms of enforcement of competition rules, the number of decisions taken increased in 2008 compared to the previous year. While the number of merger and exemption cases increased significantly, the number of cases in the area of competition infringements (cartels, vertical restraints and abusive practices) decreased. The increasing number of exemption applications is quite striking in 2008. The main explanation for this increase comes from the introduction of 40% market share threshold in the Block Exemption Communiqué on Vertical Agreements. The agreements previously exempted lost their exempted status after the introduction of the threshold. Thus, undertakings whose agreements no longer benefited from block exemption applied for individual exemption. On the other hand, the decreasing number of competition infringements is also clearly seen in 2008. An important explanation for this decrease can be associated with the files opened in 2008 but not concluded yet.

3. The TCA attached special importance on competition advocacy in 2008. In this regard, it sent
formal opinions to the requesting governmental agencies. The opinions prepared with respect to the
markets such as banking, pharmaceutical, and energy including petroleum distribution are quite striking
and have had significant influence on improving competitive conditions in the relevant markets. The TCA
also contributed to capacity building efforts for regulatory impact assessment (by the Prime Ministry),
which would institutionalize advocacy role of the TCA. In its effort, the TCA has translated the OECD
competition assessment toolkit and considers introducing a guideline on the basis of this toolkit.

4. The TCA introduced a number of important secondary legislation in 2008. In this regard, the
Guidelines on Definition of Relevant Market, Guidelines on Certain Subcontracting Agreements between
Non-competitors, Block Exemption Communiqué in relation to the Insurance Sector, Block Exemption
Communiqué on Technology Transfer Agreements were adopted and entered into force. Importantly, the
Prime Ministry sent the Bill to amend the the Act No 4054 on the Protection of Competition (the
Competition Act) extensively to the Parliament. While preparing the Bill, the TCA took into consideration
its almost 11-year experience, relevant EU legislation, work-products of international organizations such as
OECD and ICN and the recommendations of OECD Peer Review Report of 2005.

5. As part of its policy for relations with other governmental agencies, the TCA approached the
Public Procurement Agency to build a cooperation framework between the two agencies. It is expected that
such a cooperation framework will contribute to dealing with bid rigging effectively and making public
tenders more competitive. Additionally, the TCA signed a cooperation protocol with TIKA (Turkish
International Cooperation and Development Agency) to deliver technical assistance to the countries within
the framework of Turkey’s aid policy.

6. The TCA had a very active period of time in international relations in 2008. In this regard, the
TCA actively contributed to the events/projects at multilateral platforms such as OECD, ICN and
UNCTAD as well as bilateral platforms.

1. Changes to Competition Laws and Policies

1.1. Amendments in the Competition Act

7. The Competition Act was amended in January 23rd, 2008. The amendments mostly concern
administrative fines to be imposed regarding violations of the Competition Act.

8. According to the amendments of 2008, the previous fixed amounts of procedural fines in Article
16 of the Competition Act were replaced by fines that would be calculated by taking into account the
annual gross revenue. As a result of the amendment, undertakings, association of undertakings and
members of such associations shall be imposed 0.1 % of their annual gross revenue where

• incorrect or misleading information or document is provided in exemption and negative clearance
applications as well as in applications for permission to mergers and acquisitions;

• mergers and acquisitions subject to authorization are carried out without the authorization of the
Competition Board,

• incomplete, incorrect or misleading information or document is provided, or information or
document is not provided within the time specified or at all in respect of application of Articles
14 and 15 of the Competition Act regarding the powers granted to the TCA with respect to
request for information and on-the-spot inspection,

9. Whereas undertakings, association of undertakings and members of such associations shall be
imposed 0.5 % of their annual gross revenue where

• on-the-spot inspection is prevented or made difficult.

10. According to the amendment, the fines provided above can not be less than ten thousand Turkish
liras (€ 5.000). The amendment also clarifies that annual gross revenue to be taken into account for
calculation of these fines shall be the one which generated by the end of the fiscal year preceding the
decision, or where it can not be calculated, which generated by the end of the fiscal year closest to the date
of the decision.

11. Moreover, regarding the fine to be imposed when mergers and acquisitions subject to
authorization are carried out without the authorization of the Competition Board, it will be imposed on
each party in mergers whereas it will be imposed only on the acquirer in acquisitions.

12. The above fine valid for cases where on the spot inspection is prevented or made difficult can
still be imposed in the event that on-the-spot inspection is carried out by court decision.

13. The amendment also clarifies that regarding the substantive fine to be imposed up to 10% of the
annual gross revenue, the annual gross revenue shall be the one which generated by the end of the fiscal
year preceding the final decision, or where it can not be calculated, which generated by the end of the fiscal
year closest to the date of the final decision. Moreover, according to the amendment the executives or
employees of the undertaking or the association of undertakings which are detected to have had a
determining impact on the violation will be imposed fines up to 5% of the substantive fine imposed on the
undertaking or association of undertakings.

14. Previous to the amendment, the Competition Board, while deciding on the substantive fine, had
to take into account factors such as the existence of intent, the severity of fault, the market power of the
undertaking or undertakings upon which a penalty is imposed, and the severity of potential damage. The
amendment, while keeping some of these factors, also replaced certain of them and added new ones. As a
result, according to the amendment, the Competition Board has to take into account factors such as the
repetition and duration of violation, the market power of the undertaking or associations of undertakings,
their determining impact on the occurrence of violation, whether they conform to the commitments made,
whether they assist with the inspection, the gravity of the damage which has occurred or is likely to occur.

• 8 pages
• Confidential
• For Official Use Only
• December 14, 2009

Armenia	Ms. Armenuhi MKRTCHYAN Head of Consumer Protection Division Central Bank of Armenia m_armenuhi@cba.am
Armenia	Dr. Amalia SARIBEKYAN Member of the Board Central Bank of the Republic of Armenia saribekyana@cba.am
Australia	Mr. Ross JONES Deputy Chairman Australian Prudential Regulation Authority ross.jones@apra.gov.au
Brazil	Mr. Sergio ALMEIDA DE SOUZA LIMA Consultor do Presidente Central Bank of Brazil sergio.lima@bcb.gov.br
Brazil	Mr. José Alexandre CAVALCANTI VASCO Head of the Investor Assistance & Education Department Education and Investor Assistance CVM (The Securities and Exchange Commission of Brazil) vasco@cvm.gov.br
Brazil	Mr. José Linaldo GOMES DE AGUIAR Secretário de Relações Institucionais / Secretariat for Institutional Relations Banco do Brasil linaldo@bcb.gov.br
Brazil	Ms. Suzana LISKAUSKAS Head of PR Comissão de Valores Mobiliários suzana@cvm.gov.br
Brazil	Ms. Patrícia MONTEIRO General-Coordinator for Economic Issues of the Economic Department Financial Affairs Division National Secretariat for Pension Funds / Ministry of Social Security patricia.monteiro@previdencia.gov.br

Brazil	Mrs. Glenda OLIVEIRA Coordinator of the Centre of Documentation Superintendência de Seguros Privados - SUSEP Ministry of Finance gmendes@susep.gov.br
Brazil	Mr. Ricardo Luis PAIXÃO Deputy Head of Departament Banco Central do Brasil ricardo.paixao@bcb.gov.br
Brazil	Ms. Bruna ROMÃO BORGES Special Advisor for International Affairs National Secretariat for Pension Funds - Ministry of Social Security bruna.borges@previdencia.gov.br
Brazil	Maria Helena SANTANA Chair Comissão de Valores Mobiliários (CVM) Brazil exe@cvm.gov.br
Canada	Mr. Marc LEBRUN Director General Human Resources and Social Development Canada / Canada Education Savings Program Human Resources and Social Development Canada (HRSDC) marc.l.lebrun@hrsdc-rhdsc.gc.ca
Canada	Ms. Ursula MENKE Commissioner Financial Consumer Agency of Canada Menke.Ursula@fcac.gc.ca
Canada	Ms. Jane ROONEY Director, Financial Literacy and Consumer Education Financial Consumer Agency of Canada rooney.jane@fcac.gc.ca
Canada	Ms. Susan MURRAY Executive Director Task Force on Financial Literacy Secretariat Department of Finance Canada susan.murray@fin.gc.ca
Chile	Mr. Daniel GARCÍA SCHILLING Communication Director on Education Program Superintendecia de Valores y Seguros (SVS) dgarcia@svs.cl

Colombia	Ms. Diana M. MEJÍA ANZOLA Director Institutional Communications/Directora Departamento de Comunicación Institucional Banco de la República dmejiaan@banrep.gov.co
Czech Republic	Ms. Helena KOLMANOVA Director Consumer Protection Department Czech National Bank helena.kolmanova@cnb.cz
Ecuador	Ms. Monica CORDOVA PENAFIEL Técnica en Comunicación Superintendencia de Compañías smcordova@hotmail.com
Ecuador	Ms. Virginia Elizabeth VILLACIS PELAEZ Superintendencia de Compañias - Intendencia de Guayaquil Superintendencia de Compañías Virginiav@g.supercias.gov.ec
Ecuador	Ms. Anabelle VINUEZA PARRA Especialista de Control Superintendencia de Compañías fannyv@q.supercias.gov.ec
France	M. Bernard SIMLER Inspecteur général de l’Education nationale Ministère de l’Education nationale bernard.simler@education.gouv.fr
Germany	Ms. Beate FRINGS Economist International Financial System Division Deutsche Bundesbank beate.frings@bundesbank.de
Germany	Mr. Dietrich LINGENTHAL Head of Division International Financial Markets Bundesministerium der Finanzen (BMF) Dietrich.Lingenthal@bmf.bund.de
Hungary	Mrs. Judit SZOLNOKINE PAP Head of Financial Literacy Centre National Bank of Hungary szolnokinej@mnb.hu
India	Mr. K C CHAKRABARTY Deputy Governor Reserve Bank of India kcchakrabarty@rbi.org.in

India	Mr. Jaganmohan Rao GORINKA Chief General Manager Customer Service Department Reserve Bank of India gjrao@rbi.org.in
India	Mr. Subramaniam RAJENDRAN General Manager Securities and Exchange Board of India (SEBI) rajendranb@sebi.gov.in
Indonesia	Mr. Budi ROCHADI Deputy Governor Bank Indonesia rochadi@bi.go.id
Indonesia	Mr. Halim ALAMSYAH Director, Banking Research & Regulation Department Bank Indonesia halamsyah@bi.go.id
Indonesia	Mr. Pungky WIBOWO Senior Researcher Bank Indonesia pungky_pw@bi.go.id
Indonesia	Mr. Bambang ARIANTO Researcher, Financial System Stability Bureau Directorate of Banking Research and Regulation Bank Indonesia bambang_a@bi.go.id
Italy	Mr. Vincenzo NASTASI Chief Executive Svi Finance SpA (Invitalia Group) vnastasi@invitalia.it
Italy	Mr. Maurizio TRIFILIDIS Senior Director Servizio Concorrenza, normativa e affari generali Banca d’Italia maurizio.trifilidis@bancaditalia.it
Japan	Ms. Ryouko OKAZAKI Director, Promotion of Financial Education in Schools, Public Relations Department Bank of Japan & and the Central Council for Financial Services Information ryouko.okazaki@boj.or.jp
Kenya	Ms. Rose MUSONYE KWENA Head, Corporate Communication Retirement Benefits Authority (RBA) Rkwena@rba.go.ke

Mexico	Mr. Guillermo ZAMARRIPA Head of the Banking, Securities and Savings Unit Ministry of Finance and Public Credit guillermo_zamarripa@hacienda.gob.mx
Netherlands	Mr. Sander VERBAAN Senior policy advisor Dutch Ministry of Finance s.verbaan@minfin.nl
New Zealand	Ms. Diana CROSSAN Retirement Commissioner Retirement Commission diana.crossan@retirement.org.nz
Philippines	Ms. Belinda G. CARAAN Acting Deputy Director and Head, Financial Consumer Affairs Group Supervision and Examination Sector Bangko Sentral Ng Pilipinas mcaraan@bsp.gov.ph
Poland	Mr. Andrzej JAREMA Deputy Director, Department of Civil Service National Bank of Poland Sekretariat.DEW@mail.nbp.pl
Poland	Ms. Katarzyna NADUK ILICZ Financial Market Development Department Ministry of Finance katarzyna.ilicz@mofnet.gov.pl
Poland	Mr. Michal NALEPA Deputy Director of Education Department Polish Financial Supervision Authority Michal.Nalepa@knf.gov.pl
Poland	Mr. Jakub SKIBA Member of the Board National Bank of Poland JAKUB.SKIBA@NBP.PL
Portugal	Mrs. Maria Lúcia LEITÃO Deputy Head of Banking Supervision Department Banco de Portugal mlleitao@bportugal.pt
Slovak Republic	Mr. Vladimir DVORACEK Director General, Financial Market Section Ministry of Finance vladimir.dvoracek@mfsr.sk

Slovak Republic	Mr. Slavomir STASTNY Member of the Bank Board National Bank of Slovakia slavomir.stastny@nbs.sk
South Africa	Mr. Lyndwill CLARKE Manager, Consumer Education Department Financial Services Board lyndwillC@fsb.co.za
South Africa	Ms. Olivia DAVIDS Head of Department, Consumer Education Financial Services Board of South Africa oliviad@fsb.co.za
Spain	Ms. Cristina CARRILLO RIVERO Deputy Director Investors Directorate Comisión Nacional del Mercado de Valores (CNMV) carrillo@cnmv.es
Trinidad and Tobago	Ms. Elizabeth AUSTIN Manager, National Financial Literacy Programme Central Bank of Trinidad & Tobago eaustin@central-bank.org.tt
Turkey	Mr. Rifat GÜNAY Deputy Director General Türkiye Cumhuriyet Merkez Bankas/Central Bank of the Republic of Turkey rifat.gunay@tcmb.gov.tr
United Kingdom	Ms. Sue LEWIS Head of Savings and Investments Savings and Investment HM Treasury Sue.Lewis@hmtreasury.gsi.gov.uk
United States	Ms. Michelle GREENE Deputy Assistant Secretary of Financial Education U.S. Treasury Department Michelle.Greene@do.treas.gov
United States	Ms. Jeanne HOGARTH Program Manager Consumer Education and Research Section of the Division of Consumer and Community Affairs US Federal Reserve Board Jeanne.m.Hogarth@frb.gov
Venezuela	Mr. Txomin LAS HERAS LEIZAOLA Gerente de Comunicaciones Institucionales Banco Central de Venezuela tlashera@bcv.org.ve

World Bank	Mr. Richard Paul HINZ Pensions Policy Advisor, Social Protection, Human Development Network Human Development and Social Protection Department The World Bank RHinz@worldbank.org
OECD Secretariat	Mr. Aart DE GEUS Deputy Secretary-General Aart.DEGEUS@oecd.org
OECD Secretariat	M. André LABOUL Head, Financial Affairs Division Andre.LABOUL@oecd.org
OECD Secretariat	M. Bruno LEVESQUE Principal Administrator, Financial Affairs Division Bruno.LEVESQUE@oecd.org
OECD Secretariat	Mlle. Flore-Anne MESSY Principal Administrator, Financial Affairs Division Flore-Anne.MESSY@oecd.org
OECD Secretariat	Ms. Sophie SALTRE Project coordinator, Financial Affairs Division sophie.saltre@oecd.org

The US investment bank said there is a danger Britain’s toxic mix of problems will come to a head as soon as next year, triggered by fears that Westminster may prove unable to restore fiscal credibility.

“Growing fears over a hung parliament would likely weigh on both the currency and gilt yields as it would represent something of a leap into the unknown, and would increase the probability that some of the rating agencies remove the UK’s AAA status,” said the report, written by the bank’s European investment team of Ronan Carr, Teun Draaisma, and Graham Secker.

“In an extreme situation a fiscal crisis could lead to some domestic capital flight, severe pound weakness and a sell-off in UK government bonds. The Bank of England may feel forced to hike rates to shore up confidence in monetary policy and stabilize the currency, threatening the fragile economic recovery,” they said.

Morgan Stanley said that such a chain of events could drive up yields on 10-year UK gilts by 150 basis points. This would raise borrowing costs to well over 5pc – the sort of level now confronting Greece, and far higher than costs for Italy, Mexico, or Brazil.

High-grade debt from companies such as BP, GSK, or Tesco might command a lower risk premium than UK sovereign debt, once an unthinkable state of affairs.

A spike in bond yields would greatly complicate the task of funding Britain’s budget deficit, expected to be the worst of the OECD group next year at 13.3pc of GDP.

Investors have been fretting privately for some time that the Bank might have to raise rates before it is ready — risking a double-dip recession, and an incipient compound-debt spiral – but this the first time a major global investment house has issued such a stark warning.

No G10 country has seen its ability to provide emergency stimulus seriously constrained by outside forces since the credit crisis began. It is unclear how markets would respond if they began to question the efficacy of state power.

Morgan Stanley said sterling may fall a further 10pc in trade-weighted terms. This would complete the steepest slide in the pound since the industrial revolution, exceeding the 30pc drop from peak to trough after Britain was driven off the Gold Standard in cataclysmic circumstances in 1931.

UK equities would perform reasonably well. Some 65pc of earnings from FTSE companies come from overseas, so they would enjoy a currency windfall gain.

While the report – “Tougher Times in 2010” – is not linked to the Dubai debacle, it is a reminder that countries merely bought time during the crisis by resorting to fiscal stimulus and shunting private losses onto public books. The rescues – though necessary – have not resolved the underlying debt problem. They have storied up a second set of difficulties by degrading sovereign debt across much of the world.

Morgan Stanley said Britain’s travails are one of three “surprises” to expect in 2010. The other two are a dollar rebound, and strong performance by pharmaceutical stocks.

David Buik, from BGC Partners, said Britain is in particularly bad shape because the tax-take is highly leveraged to the global economic cycle: financial services provided 27pc of revenue in the boom, but has since collapsed.

The UK failed to put aside money in the fat years to offset this time-honoured fiscal cycle. It ran a budget deficit of 3pc of GPD at the peak of the boom when prudent countries such as Finland and even Spain were running a surplus of over 2pc.

“We need to raise VAT to 20pc and make seriously dramatic cuts in services that go beyond anything that Alistair Darling or David Cameron are talking about. Nobody seems to have the courage to face up to this,” said Mr Buik.

The report coincided with news that Britain is now officially the only G20 country still to be in recession. Canada reported that its economy grew by 0.1pc in the third quarter. Britain, by contrast, shrank by 0.3pc, the latest estimates show.

© Telegraph Media Group Limited 2009

MEXICO CITY, Aug 31 – The Organization for Economic Cooperation and Development has moved an international meeting on tax havens to Mexico City from the Pacific resort of Los Cabos due to an approaching hurricane.

Delegates from around 70 OECD and non-OECD countries had already started arriving in Los Cabos, on the southern tip of Mexico’s Baja California Peninsula, for the talks on Tuesday and Wednesday, but dangerous Category 4 Hurricane Jimena was forecast to hammer the resort on those days.

The meeting was “transferred to Mexico City because of the threat of severe damage posed by Hurricane Jimena,” the Paris-based OECD said in a statement.

OECD head Angel Gurria will lead the two-day talks, aimed at persuading more countries to share tax information.

Residents and tourists in the Los Cabos area stocked up on food and fuel or cut short their vacations after the Mexican government issued a hurricane warning. The U.S. National Hurricane Center said people should take precautions to safeguard their lives and property.

Category 4 hurricanes like Jimena, which was packing 145 mph (230 kph) winds, are “extremely dangerous” according to the hurricane center and can cause devastating damage on land.

Much of Baja California is sparsely populated desert and mountains, but Los Cabos is a lively resort area popular with U.S. tourists for its world-class golf courses, upscale hotels, yachting and beaches.

The hurricane center said Jimena could dump 5 to 10 inches (13 to 25 cm) of rain on the southern end of the peninsula. (Reporting by Tomas Sarmiento in Mexico City and Brian Love in Paris; editing by Mohammad Zargham)

© Thomson Reuters 2009