rules of its former regulators, the Life Assurance and Unit Trust Regulatory Organisation (Lautro) and the Personal Investment Authority (PIA) in failing to disclose the risk of the existing GAR policies in the Product Particulars, Key Features and With-Profits Guide to new non-GAR policy holders. This was followed in September by the Corley Report on behalf of the Institute of Actuaries, which recommended, amongst other things, that the Appointed Actuary should require that there is a process for reviewing communications to policyholders, and should resist holding a dual role as Chief Executive, and that his work should be subject to peer review. In October, the Baird Report was published. This covered the Financial Services Authority's regulation of Equitable from 1 January 1999 to 8 December 2000, when the Society closed to new business. The report was produced by the FSA's director of internal audit with the help of independent accountants and lawyers. The review found that – with hindsight – there had been some "deficiencies" on the part of the FSA in the discharge of their regulatory responsibilities, but also stated that "the die had been cast" by the time the FSA had assumed regulatory responsibility for the Society, in relation to those who had already invested in Equitable. The Penrose report, 2004 The Penrose report, commissioned by the Treasury in August 2001 and expected in 2002, was finally published in March 2004 after delays due to vetting by Treasury lawyers. The 818-page report found that the company had made over-generous payouts to policyholders, reaching the stage where "The Society was under-funded to the extent of £4½ billion in the summer of 2001" (chapter 19, para 82). Penrose said: "Principally, the Society was author of its own misfortunes. Regulatory system failures were secondary factors". He also accused the former Equitable management team of "dubious" practices and nurturing a "culture of manipulation and concealment". The Report was debated in parliament on 24 March 2004. European Parliament investigation, 2007 In June 2007 the European Parliament issued a 385-page report on Equitable Life. Its fifteen-month investigation followed the implementation in July 2004 of EC Directive 92/96/EEC (the Third Life Directive or 3LD), which governs the single market in life insurance. This directive required the UK, where Equitable's headquarters were, to supervise its "entire business", and curtailed the supervisory power of other EU countries where Equitable operated. The EU Parliament's remit was to investigate,