I'm going to start with some high-level answers to that, then I might turn Madam Cabana or Ms. Loutsiv to expand.
What we found—and we reported this in paragraphs 30 and 31—was there was work to be done to set the procedures for risk assessment and to identify how the procedures for model development, ownership and maintenance, independent validation, monitoring and reporting would be done. It's not to say that they don't have a model validation procedure; it's just that there were improvements that could be made in these areas and we felt that with improvements in these areas, there could be consistency across the corporations, business units and investment units.
Ms. Cabana, would you like to add to that?