March 7, 2013
Ms. Amy L. Starr
Chief Office of Capital Markets Trends
Division of Corporation Finance
US Securities and Exchange Commission
Washington, DC 20549
424 Prospectuses relating to Registration Statement on Form F-3ASR
Filed January 11, 2012
File No. 333-178960
Dear Ms. Starr:
Thank you for your letter of February 21, 2013. We have reviewed your comments and confirm that we will implement changes to future prospectus supplements to reflect those comments. We are currently engaged in drafting efforts to revise and conform our disclosure. Due to the wide variety of notes we offer, as well as required changes to our internal operating procedures, we expect to implement changes over a period of time.
Please do not hesitate to contact us if you have questions or comments or would like to discuss further the contents of this letter.
Very truly yours,
By:/s/ Gordon S. Kiesling
Gordon S. Kiesling