Partly in pursuit of that goal, the qualification standards have been set very high for the Advanced IRB approach and, in truth although perhaps not in public perception, for the Foundation IRB approach as well. The standards are an amalgamation of the best practices of many banks.
No one bank follows all of them and, hence, at this moment, no bank meets all the IRB standards, especially for the advanced approach. Let me also say that again: At this moment and with current systems, no bank in the United States likely would qualify to use the Advanced IRB approach.