The proposal basically mirrors how our institution is currently underwriting and risk rating commercial credits. The proposal formalizes portions of the process and should be relatively easy to implement!

The proposal takes out much of the ambiguity in the classification process and greatly enhances the focus on the default element, something that has been needed for years.

There is a down side in that the industry may experience a down turn in classification statistics as many collateral lenders transform to underwriting for default.