The document discusses the Standardised Measurement Approach (SMA) for operational risk capital requirements proposed by the Basel Committee. It analyzes key aspects of the SMA methodology and proposes alternatives. Specifically, it identifies limits around the inclusion of loss data, qualitative asymmetry in loss histories, and flexibility in defining loss history depth. It proposes aligning both business indicator and loss component histories to a minimum 10-year period. It also discusses limits around the undefined de-minimis threshold for loss data collection and proposes calibrating it based on materiality and banks' risk appetites.