(4) Furthermore, the deadline for the correction of the excessive deficit was widened to up to two years in case of “special circumstances”, which are identical to the “other relevant factors” mentioned above. (5) One change which is more significant than the extension of deadlines but has received less public attention is the possibility now provided for repeating procedural steps.
Capital regulations cannot be extremely simple and at the same time appropriately sensitive to the multifaceted operations and risks of the LCBOs. We could try to apply simple rules to complex organizations, but the result could be easily predicted: We would not solve the problems of capital arbitrage and risk sensitivity, and the rules would treat some operations at some banks unfairly.