Mr. Jim O'Keeffe:

The types of cases we are talking about involve a dual piece. We would call it "the business", for the lack of a better term. The case manager would fill out the proposal and recommend it before the decision. When I am talking about reporting that is going to the board, etc., the credit risk function in the type of cases we are talking about will adjudicate before a decision is made. There are two lines involved. Depending on the framework, that may actually go to a committee for a decision. That committee will be made up of credit and customer-facing people, and will primarily be chaired by the risk function. The risk function is still within the bank and sits within the chief risk officer's world, which is defined under regulation as a preapproved control function, PCF, with very specific independent authority in that regard. Before the decision is made in the types of cases we are talking about, there is a dual piece.