1. In effect, the Simplified Approach reduces undue regulatory burden on Category 3A firms to reflect more appropriately their risk profile.
2. In relation to (3) and (4), the Regulator may consider granting its approval for a change of approach if it is satisfied that there are no regulatory capital arbitrage opportunities. Firms should be able to demonstrate to the Regulator solid and reasonable grounds to be able to move from one approach to the other. For instance, in assessing whether or not to grant approval, the Regulator may consider whether or not there has been a material change in the business of the firm.