Admittedly, this policy path chosen by U.S. supervisors may present some important choices for foreign banks that operate a U.S. bank subsidiary. For foreign banks operating under A-IRB and AMA on a consolidated basis under their home country rules, choosing A-IRB and AMA for their U.S. bank subsidiaries would not present any particular problems.
Equity funds instead of credit funds shall be established for the real estate industry if the developers’ problem of insufficient equity needs to be resolved via trust funds, so that funds owners shall bear the investment risks at the same time when they enjoy the investment returns. The real estate trust is in essence an industrial investment fund.