What the banking industry (and others) told the Basel regulators

The Central Bank of Malta noted reputational risk was not included in the Basel II definition. Although difficult to measure, reputational risk could have significant adverse effects which far outweigh the actual losses arising from operational risk and this should not be ignored.

The Bank of Thailand said since Basel II defines operational risk to include legal risk, the definition should be sufficiently clear to prevent any additional capital charge arising from difficulties in distinguishing

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