Thus, what may be perceived as a raising of the bar every year is better understood as our effort to provide a demanding, but still realistic, glide path for firms to reach that goal. We do, however, expect firms to continue to make steady progress each year.
Second, the horizontal nature of the qualitative assessment does not mean that every year one or more firms must receive an objection on qualitative grounds. The comparative approach helps ensure that firms are evaluated consistently and fairly. And it does allow us to see where specific firms may be outliers from good practices followed in the rest of the industry.