We are, for example, prepared to explore the possibility of allowing U.S. subsidiaries of foreign banks to use conservative estimates of LGD and EAD for a finite transitional period when data are not yet available for parts of some portfolios. This possible option would, if adopted, apply equally to fully domestic U.S. banks adopting A-IRB.
I can understand that the market participants with global businesses would like to see progress towards a global infrastructure; but they have also been very clear in telling us that the major cross-border costs in securities markets arise from lack of harmonisation.