Importantly, that effort has adopted an approach to credit risk on instruments held in the banking book that differs from the current capital rules applied to instruments held in the trading book under the 1998 Market Risk Amendment (MRA) to the Basel Accord.
Importantly, the CRA database we have constructed confirms that the proposed retail lending metrics correlate well with past ratings of bank performance (figure 3). The specific thresholds that would establish a presumption of satisfactory performance could be informed by  examiner. The minimum activity threshold would be calibrated for geographies and different market conditions over time.