The determination of capital adequacy is a combination of quantitative analysis and the exercise of sound business judgment. It includes modeling for portfolio credit risk, market risk, and operational risks. We evaluate and provide analyses of regulatory and economic capital requirements, given asset quality and problem asset projections under various stress scenarios. Determining capital adequacy also includes non-modeled risks such as reputational risk and business-strategy risk. Overall, we review and develop a capital policy with appropriate metrics, targets and limits—developing a road map in conjunction with the company’s strategic business planning.