This was in part because I am acutely aware of the challenges involved in building wholesale payments capabilities and appreciate that, and proofs of concept can be both complex and take time to develop. As an example, the requirements for such an endeavour need to be carefully defined, prioritised, and mapped into functional and technical specifications.
Devising such a charge has proved extremely difficult because of a lack of both an agreed-upon methodology and credible industry data. This has required the adoption of a strategy to permit banks to use their own internal measurement approaches--subject to quantitative and qualitative criteria and, on a transitional basis, to a minimum or floor capital charge.