An excellent post over at Ops Risk and Compliance regarding the US implementation. It makes many of the points I have previously made – and goes a bit further.
After quantative [sic] impact studies, advanced notices of proposed rulemaking, numerous consultation documents, incalculable titbits of contradictory information from a menagerie of regulators (some of whom apparently think Basel II: The New Accord is a movie – sequel to the 1988 worldwide smash hit original) we finally have an NPR out there that everyone has agreed on.
And in the same spirit of cooperation, compromise and conciliation with which the regulators thrashed out this NPR, the responders have answered in a similar spirit of agreement. That is, they all agree its pretty crap.
Little more to be said, really. Like the bit about the movie title.