These discussions, which are ongoing, have significantly changed some of the data provided, and some modifications are still coming in. Nonetheless, even with these revisions, two conclusions are already clear. First, the dispersion among the banks in their estimates of the key parameters that would be used to calculate Basel II capital requirements was quite wide - much wider than expected.
Second, the implied reductions in minimum regulatory capital were often substantial - far more than previous quantitative impact studies, both here and abroad, had suggested. As responsible and prudent regulators, we believe it is appropriate to improve our understanding of these results and to see whether changes might be needed in our proposals.