The Financial Services Act 2012 ('the Act') introduced: "important changes to the regulatory framework of financial services in the United Kingdom, many of which affect the Bank of England. The Financial Services Authority (FSA), which was previously responsible for regulation of financial firms from both a 'prudential' and 'conduct' perspective, will cease to exist." See Bank of England Quarterly Bulletin 2013 Q1, page 20 Even though immense changes have taken place since 2008, this publication, as well as the entire study, focusses on, considers and necessitates an in-depth analysis of the structure and system of regulation which was in force in the UK, Germany, Italy and the U.S between 2004 and 2008. Through a comparative analysis of selected jurisdictions, the book examines how the external auditor could assist the then existing regulator, Financial Services Authority (FSA), the UK's financial services regulator, in carrying out its regulatory and supervisory functions. It also considers how the FSA could implement its supervisory and enforcement tools in addressing the issue of audit liability.