Iain James MacKay
Management
So certainly, when you look at CRA [ph] thinking around leverage, I mean I think one thing that's worth commenting is that, if you looked at us from a Basel III end point basis, we're sitting on a leverage ratio of 4.1%, 4.2%, which is probably why there's been obviously no mention or discussion of this topic with us and the PRA, because I think they look at the overall leverage position under a fairly stressed sort of hybrid PRA, CRD IV calculation as being in pretty good shape. When you then think about how it works across the different portfolios and standardized versus advanced, again, it's a portfolio-by-portfolio story. I mean we probably look at standardized against our U.S. mortgage portfolio and think that standardized is quite a good idea, whereas you might look at it against a particularly low-risk portfolio, like your Hong Kong mortgages, and go, well, this probably doesn't make a great deal of sense. I think one of the things that the regulatory community is just struggling with just now, which is something the banks can absolutely help them with, and I think we, in particular, have taken significant steps in this regard over the course of last year end, is just much greater disclosure and understanding about what's going on in the risk-weighted asset models, in terms of roll-forward analysis, RWA density. And a lot of those disclosures were provided through implementing enhanced disclosure task force recommendations, which came out. And I think if we could get -- certainly, all the U.K. banks have made good progress in that respect, and I suspect they'll make even more progress as we work through 2013. Unfortunately, outside the U.K., there hasn't been much of a drive towards broad-based adoption of those recommendations. Until we get the banking industry being, frankly, just a lot more transparent about what's going inside the risk-weighted asset models, one can perhaps appreciate the regulators' desire to look at it in a different basis. But I think our own view would be, banging out a standardized measure is simply banging out another measure. It doesn't really help the risk management within the banking sector. I would be a very strong advocate for the fact that an internal ratings-based approach, well-constructed models, stress tested, analyzed with the right level of transparency and disclosure gives you a much better understanding of the risk equation within a bank's balance sheet than adopting a broad based, standardized approach, which is not terribly risk sensitive. And the same would go for, frankly, a leverage ratio. It's a great backstop measure for the economy. You might even argue it's a good backstop measure for an individual institution, but it's not, particularly, risk sensitive; in fact, it's not risk sensitive at all.