It is true that especially with new regulation the rules and definitions aren't fully clear but banks need to somehow comply. In those cases showing the effort

It is true that especially with new regulation the rules and definitions aren't fully clear but banks need to somehow comply. In those cases showing the effort that you are engaged in getting there helps, you make an interpretation and go with it, but you might need to change when there is clarity on the proper interpretation, banks are looking at what other banks are doing, external specialists are hired. But it still remains messy.