These include: •  Raising the quality, consistency and transparency of the Tier 1 capital base;  •  Introducing a leverage ratio as a supplementary measure to the Basel II risk-based framework;  •  Implementing a minimum global standard for funding liquidity, and  •  Creating a framework for countercyclical capital buffers.
The census data back-up was not perfect but it was much better than nothing. Reputational damage is lessened if measures exist yet are inadequate compared with the situation where the risks were unidentified and uncontrolled, i.e. mitigations were absent. For example, The ACC privacy breaches were accentuated by a lack of privacy management.