Mr. Eugene Sheehy:

Yes and I've two views on it. I was on the board of a US bank at the time and they decided to ignore it and the regulator over there said, "You're supposed to do it, but in actual fact you can ignore it" and that's what happened over in America. Here, when like ... I agree with everything Mr. Buckley said, it's a totally nonsensical accounting standard from a banking point of view. It may be appropriate for other industries but for banking it was totally nonsensical. There was a board discussion during my period there. I haven't seen it noted but I did talk to an official in the bank who would have been an executive director at the time and we did discuss it. And we discussed whether we should go to the regulator with our concerns and given that no European country other than Spain had deviated from it, we decided there was no point. Now, I then tried to research what had happened in Spain and why it happened in Spain and there is a very particular reason. For historical reasons, Spanish banks were required to hold very large shareholdings in large Spanish companies. When their tier 1 was being calculated, the equity value of those holdings, which are basically stocks and shares, were included in their total capital. That didn't meet the international standard for tier 1 because of its volatility so the Spanish authorities were able to make the case that, "We have this historical volatile piece of capital in our banks balance sheets - we need the extra comfort of not changing", in effect and having cross cyclical provisions to bolster their resilience.