22 March 2007
The Office of the Controller of the Currency 250 E Street, SW Washington, DC 20219 [12 CFR Part 3; Docket No. 06-09 RIN 1557-AC91]
Robert E Feldman Executive Secretary, FDIC 550 17th Street, NW Washington, DC 20429 [12 CFR Part 325; RIN 3064-AC73]
Jennifer J Johnson Secretary, Board of Governors of the FED 20th Street and Constitution Avenue, NW Washington, DC 20551 [12 CFR Parts 208 and 225; Regulation H and Y; Docket No. R-1261]
Regulatory Comments Chief Counsel’s Office, OTS 1700 G Street, NW Washington, DC 20552 [12 CFR Part 566; RIN 1550-AB56]
Dear Sirs & Madam,
NOTICE OF PROPOSED RULE-MAKING (NPR) - BASEL II
Thank you for the opportunity to comment on your proposals for implementing the Basel Accord within the United States.
By way of background, the Royal Bank of Scotland Group (RBSG) is one of the top ten global banks. We have significant activities in North America, including Retail and Commercial Banking, Asset Finance and Capital Markets operations. The largest single business, measured by assets, is Citizens Financial Group, Inc., a Providence-based commercial bank holding company that operates over 1,600 Citizens Bank and Charter One branch offices in Connecticut, Massachusetts, New Hampshire, New Jersey, Rhode Island, Pennsylvania, Delaware, New York, Vermont, Illinois, Indiana, Michigan, and Ohio.
The majority of the Group's exposures are already covered by the EU Capital Requirements Directive (EU CRD). Citizens, with over $160 billion in assets, falls outside the "top 10" group of core banks mandated to operate the advanced approaches for credit and operational risk in 2009. However, we are planning to move the US business to Basel II during 2009. Given our