My general reaction to that would be yes. It's hard to know if you are meeting your regulatory responsibilities if you haven't set baselines. If you haven't established the level of activity--which of course can vary over time, as risks change and situations change--if you haven't established the baseline, then how do you know if you're allocating enough resources to it or not, and how do you know if you're carrying out the level of activity you think is appropriate? So I would say yes.
On February 12th, 2007. See this statement in context.