Comment on Proposed Supervisory Guidance for Internal Ratings Based Systems for Credit Risk

Deutsche Bank e Bank AG New York, 60 Wall Street, New York, NY 10005 May 29, 2007 Re: Comment on Proposed Supervisory Guidance for Internal Ratings Based Systems for Credit Risk, Advanced Measurement Approaches for Operational Risk, andy Review Process (Pillar 2) Related to Basel II Implementation Board Docket Nos. OP-1277, OCC Docket Nos. OCC-2007-004, OTS Nos. 2007-06 Jennifer J. Johnson Robert E. Feldman Secretary, Executive Secretary Board of Governors Attn; Comments, of the Federal Reserve System Federal Deposit Insurance Corp, 20th Street & Constitution Ave, NW 550 17th Street, NW Washington, D.C. 20551 Washington, D.C. 20429 Office of the Comptroller Regulation Comments of the Currency Attn; 2007-06 250 E Street, SW Chief Counsel's Office Mail Stop 1-5, Office of Thrift Supervision Washington, D.C. 20219 1700 G Street, NW, Washington, D.C. 20552 Ladies and Gentlemen; Deutsche Bank appreciates the opportunity to comment on the Joint Supervisory Guidance ("Supervisory Guidance") relating to Basel II Implementation. In order to communicate effectively its major concerns to the agencies while providing supporting technical detail, Deutsche Bank has divided its comments between this letter and a more detailed Supplemental Memorandum attached as Appendix A hereto. Deutsche Bank is responding to the Supervisory Guidance consultation document while maintaining its position in relation to the scope and content of the Basel II Joint Notice ...