Public Comment, Supervisory Guidance for Internal Ratings-Based Systems for Credit Risk, Wachovia

May 29, 2007 Ms. Jennifer J. Johnson Office of the Comptroller of the Currency Secretary 250 E Street, S.W. Board of Governors of the Federal Reserve Mail Stop 1-5 System Washington, DC 20219 20th Street and Constitution Avenue, N.W. Docket No. OCC–2007–0004 Via E-mail: regs.comments@occ.treas.gov Washington, D.C. 20551 Docket No. OP-1277 Via E-mail: regs.comments@federalreserve.gov. Mr. Robert E. Feldman Regulation Comments Executive Secretary Chief Counsel’s Office Attention: Comments Office of Thrift Supervision Federal Deposit Insurance Corporation 1700 G Street, N.W. 550 17th Street, N.W. Washington, DC 20552 Washington, DC 20429 Attention: No. 2007-06 Via E-mail: regs.comments@ots.treas.gov Attention: Basel II Supervisory Guidance Via E-mail: Comments@FDIC.gov Subject: Comments on Proposed Supervisory Guidance For Internal Ratings-Based Systems for Credit Risk, Advanced Measurement Approaches for Operational Risk, and the Supervisory Review Process (Pillar II) Related to Basel II Implementation, 72 FR 9084, February 28, 2007 Ladies and Gentlemen: Wachovia welcomes the opportunity to comment on the proposed Supervisory Guidance for implementing the Basel capital rules in the United States. We have participated throughout the development of updated capital requirements in the United States and internationally, and we believe that constructive dialogue improves regulation. This is especially true with ...