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On September 27, 2004, the Governor of the State of California signed into law Assembly Bill 1000, making changes affecting the substance and timing of the annual disclosure requirements under the controversial California Corporate Disclosure Act (the "California Disclosure Act") that was enacted in late 2002. The amendments took effect immediately and must be observed by all corporations that are incorporated or have qualified to do business in California.

In late March, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Office of Thrift Supervision (the "Agencies") issued the Interagency Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice (the "Guidance"). 70 Fed. Reg. 15736 (2005). The Guidance requires the development and implementation of a response program to address unauthorized access to, or use o