Let me urge all of you to follow the example of some of you and move quickly in this direction. Data storage is extraordinarily cheap these days, but we all know that extracting and organizing the right data from existing systems is very expensive and often painful. Nonetheless, the contribution of better data to sound risk management will undoubtedly prove to be extremely valuable.
As you develop your own plans, let me emphasize that supervisors will be looking for a committed and integrated response by IRB banks. Focusing IRB efforts in a compliance unit that seeks to meet the letter but not the spirit of the IRB standards will not be welcome. The details of what we will expect are, of course, still being developed.