Royal Bank of Scotland is one of the few global lenders that has yet to settle with U.S. regulators on the pre-financial crisis sales of toxic mortgage bonds. Perhaps now the bank is gearing up to do so, based on reports that RBS is considering taking a multi-billion dollar charge in the 4th quarter. Equity analysts anticipate that a settlement deal would cost RBS around $3.8 billion.

RBS, which is largely owned by U.K. taxpayers, might base such a provision on Deutsche Bank’s $7.2 billion settlement and Credit Suisse Group AG’s $5.3 billion accord with the U.S. Justice Department. Before taking a provision, RBS would need approval from its non-executive board and external auditors, according to a person with knowledge of the matter. RBS must also consider that President Elect Donald Trump may make changes at the DOJ that could affect banking industry penalties, the person said.

Two reasons that senior RBS executives are said to favor such a Q4 charge: (i) the bank is on-track for a 2016 net loss; and, (ii) any provision before a settlement is reached would reduce the impact on financial performance in 2017.

 “Trying to put more of these one-time items into the rear view mirror, of course, is helpful to any normalization of the investment case,” said Barrington Pitt Miller, an analyst at Janus Capital Group in Denver. “RBS may be able to construct a sensible case with their auditors and suggest that they now have a better basis for calculation of a potential penalty, against U.S. and now non-U.S. banks in the RMBS case.”