**Calculation of Operational Risk RWA**

A bank would calculate its risk-based capital requirement based on the average of the previous three years'
positive gross income multiplied by 15 percent.

For example, at year-end 2009, a bank would use gross income for 2007, 2008, and 2009 to calculate the capital
requirement for all of 2010.

Gross income would equal a bank's total net interest income, plus non-interest income, minus income from
insurance and reinsurance activities.