And, as I want to underline, the purpose of developing improved measurement techniques is to use them as a means to the end of better overall operational-risk management. The AMA thus provides banks with the flexibility to parse out the operational risk capital charge in a manner that is reasonable and comprehensive.
To be sure, there remains the question of how certain components of an AMA, such as external data and scenario analysis, are expected to be used in arriving at an appropriate level of operational risk capital.