Client Alert

| June 22, 2009

Consob’s Careful Eye on Liquidity

Consob communication n. 9053316 of 8 June 2009 (the "Communication") sets out detailed disclosure requirements applicable to certain public offers and listings (in Italy) of debt securities. In particular, the Communication is tailored to those debt issues contemplating certain undertakings to provide liquidity on the securities. It follows that, based on an initial intrpretation, the Communication should not apply to: (i) debt issues where there is no such undertaking, and (ii) issues of non-equity securities other than debt (such as certificates).

This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent. For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383