Relaxed Deregistration Requirements for Non-U.S. Issuers

On December 23, 2005, the SEC proposed new rules which, if adopted, would facilitate the process for non-U.S. issuers to deregister their securities under the Securities Exchange Act of 1934 and thereby terminate their ongoing SEC periodic reporting obligations. The new rules propose more flexible standards, based on U.S. market interest in a non-U.S. company's securities, for exiting the SEC reporting system, and a more lenient methodology for determining a non-U.S. company's level of U.S. ownership. The proposal will be subject to public comment until Feb. 28, 2006. We expect that these rule proposals will be studied with great interest by
1 ADR issuers that in the past have wanted to de-register and/or de-list their ADRs from U.S. trading markets
2 DR issuers that have in the past been reluctant to have SEC registered and/or U.S. listed ADR programs for fear that they will never be able to exit the U.S. system under the current rules' stringent standards

Following are briefings developed by leading legal experts highlighting the key aspects of these new rules.

SEC Proposes to Relax Deregistration Requirements for Non-US Issuers
Thacher Profitt & Wood, December 2005

SEC Proposes Rule to Facilitate Exit from U.S. Exchange Act Registration and Reporting Requirements
Patterson Belknap Webb & Tyler LLP, December 2005


Copyright ©2006 Citibank, N.A. CITIGROUP and Umbrella Device are trademarks and service marks of Citigroup Inc. or its affiliates and are used and registered throughout the world. The above information is being provided solely for information purposes by Citibank, N.A. At the time of publication, this information was believed to be accurate, but Citibank, N.A. makes no representation or warranty as to correctness of the information set forth above. The above information does not constitute a recommendation, solicitation or offer by Citibank, N.A. for the purchase or sale of any securities, nor shall this material be construed in any way as investment or legal advice or a recommendation, reference or endorsement by Citibank, N.A.