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As institutions grow in sophistication and evolve generally, their calculations should grow with them. While de novo institutions may be forced to use peer data to gather some form of loss experience, it is expected that they graduate to the historical loss methodology once they have sufficient loss experience. Likewise for longstanding institutions, as their data gathering processes become more advanced, they should switch to a more comprehensive analysis in order to have an ALLL that paints a better picture of the true credit risk to which they are exposed.