This can lead to a fundamentally misconstructed comparison. Cost savings recovered can be estimated but you can't really estimate what customer costs it headed

This can lead to a fundamentally misconstructed comparison. Cost savings recovered can be estimated but you can't really estimate what customer costs it headed off. If it cost $1M of compliance, but successfully caused banks to avoid behavior that would have cost $100M to customers, that would be great. But, you only get visibility on recovery from violations. So you have at least a three term cost balance, for which only two terms are even visible.