When deciding whether our large, internationally active banks should have access to a standardized approach, the agencies will need to consider a number of important issues: whether such an approach would accommodate the risks those banks take, now and in the future; whether it would provide adequate risk sensitivity; whether taking the time needed to develop an appropriate U.S. version of the standardized approach would unduly delay the Basel II implementation process; whether the standardized approach would be useful on a transition basis in order to give some banks more time to prepare to use the advanced approaches; and, finally, whether the marketplace would find such an option for those banks meaningful and acceptable.
We are aware that some institutions have concerns, which they have expressed in formal comment letters, about areas in which the Basel II NPR diverges from the Basel II 2004 Mid-year Text.