April, 2009
Response to BCBS 150 (Securitization Capital Requirements)
PDF 412K

March 26, 2007
NPR Response
PDF 460K

September, 2006
Future Margin Income and the EL Charge for Credit Cards in
Basel II

January 18, 2006
Risk-Based Capital Guidelines; Capital Adequacy Guidelines;
Capital Maintenance: Domestic Capital Modifications
Risk Management Association
PDF 260K

September 2005
Analysis of QIS4 Results versus Internal Economic Capital 
Calculations -- Level and Diversity
Risk Management Association
PDF 248K

August 2005
Downturn LGDs for Basel II
The RMA Capital Working Group
PDF 156K

January 2005
Response to the Proposed U.S. Supervisory Guidance for Retail
Credit Risk Capital under the Basel II Framework
The RMA Capital Working Group
PDF 272K

March 2004
Response to the January 2004 Changes to the Basel Securitization Framework

March 2004
Industry Practices in Estimating EAD and LGD for Revolving
Consumer Credits--Cards and Home Equity Lines of Credit
PDF 138K

March 12, 2004
Capital Treatment of Credit Cards and Securitized Card Receivables

December, 2003
Response to the October 11, 2003 Basel Treatment of EL and UL
Risk Management Association
Word 79K

November, 2003
RMA Response to the ANPR and Supervisory Guidance Document
PDF 304K

July, 2003
Response to Basel's Third Consultative Paper On the New Capital Accord
Word 181K

March 2003
Measuring Credit Risk and Economic Capital in 
Specialized Lending Activities - Best Practices
PDF 423K

February, 2003
Retail Credit Econmic Capital Estimation -- Best Practices
Risk Management Association
Executive Summary
Full Paper
742K Zip

May 3, 2002
Response to Basel's Proposals for Allocating Capital to Securitizations
The Risk Management Association
PDF 486K

November, 2001
RMA Response to the Basle Working Paper on the IRB Treatment of Expected Losses
 and  Future Margin Income
PDF 236K

May 31, 2001
RMA Response to Basel II
PDF 524K

December, 2000
Supervisory Accreditation Procedures for a Risk-Characteristic-Based
Regulatory Capital Framework

December, 2000
Credit Risk Capital for Retail Credit Products:
A Survey of Sound Practices
PDF 128K

November, 2000
EDF Estimations: A "Test-Deck" Exercise (The RMA 
Capital Working Group) The RMA Journal
PDF (48K)

June 9, 2000
The Effects of Term on Economic Capital Allocations for Credit Risk
PDF 172K

June 7, 2000
Response to U.S. Agencies' Joint Notice of Proposed Rulemaking:
Risk-Based Capital Standards;
Recourse and Direct Credit Substitutes

March 30, 2000
Response to the Basel Committee's 
Consultative Paper on
A New Capital Adequacy Framework
PDF 245K