We have heard from a number of foreign banks that complying with these requirements is unworkable in practice, and we are considering ways to address this impracticality. One possibility that has been suggested by market participants is a simple approach that focuses on the risk of the booking location.
***  Another reason for the discussion has recently been the low-interest rate environment which now prevails in much of the developed world. This situation has focused the attention of economists to the so-called zero lower bound of interest rate policy.