We encouraged the PRA to introduce its LE regime with the introduction of Basel 3.1 to avoid unnecessary duplication of model approval requests. We suggested that the Non-Core LE Group limit should either be removed, or failing that, increased to 350% to compensate for the removal of the Internal Models  method for securities financing transactions. Similarly we proposed the introduction of a short term allowance soft limit for trading book exposures in excess of the 25% LE limit.