This Client Alert is a summary of important observations contained in the response of the Financial Services Agency of Japan (“FSA”) to public comments on proposed amendments to the various financial regulations of Japan in response to the AIJ scandal and is intended as a follow up to our Client Alert issued on November 19, 2012 regarding the proposed amendments to asset management regulations (“Amendments”) as a result of the AIJ scandal.

On December 13, 2012, the FSA issued amendments to various Cabinet Office Ordinances (naikaku furei) and Supervisory Guidelines (kantoku-shishin) regulating the asset management business in Japan and at the same time released its answers to the public comments on the proposed language of the amendments. Although the FSA revised a small portion of the proposed language of the amendments based on the public comments, there was no material change to the content of the regulations as originally proposed. Nevertheless, in some areas the FSA’s answers to public comments did help clarify the FSA’s position as to the meaning and intent of the amendments.

References in the text below are references to the numbered comments in the release issued by the FSA (http://www.fsa.go.jp/news/24/syouken/20121213-2/01.pdf). Please note that this Client Alert does not cover all aspects of the amendments. Please consult your adviser when you prepare to comply with the new rules.

Please see full alert below for more information.