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Chris Caldwell Comment On Special Notice – 10/21/22

Chris Caldwell
N/A

Modernising reporting instructions is a key pillar of the FCA’s work, alongside the Bank of England, to transform data collection. The other pillars of our Transforming Data Collection programme are integrated reporting and data standards, which we believe will collectively support us to achieve a vision of digital regulatory reporting and digital regulation. Your initiative is a hugely interesting and important development in modernising reporting instructions and in pursuit of the digital regulatory reporting and digital regulation vision. Whilst there were clearly challenges to developing this initiative (manual tagging particularly), it brings to life some early possibilities of the machine-readable rulebook, which in turn supports the case for change and helps a larger number of people understand the possibilities from work in this field. In the Digital Regulatory Reporting work carried out in the UK by the FCA, alongside the Bank of England, the cost of creating the digital version of the rules manually was seen as a key challenge. The DRR viability assessment judged that: “Ideally, the production of these digital rules from the current natural language version of the rules would be automated, making the subsequent component of the approach (standardising the description and identification of data) easier.” I believe this aligns with your experience in tagging the rules and therefore reaffirms my view that whether existing technology can accurately produce digital rules in a low-cost way, is ultimately a vital question to answer when deciding at what point to attempt to broaden the implementation of digital regulation. This might mean the next valuable steps should focus on how to efficiently create digital rules, and how effective and efficient that process can be made with currently technology, in order to better understand the cost side of the cost-benefit equation. However, given the recent advances and releases in the AI field, I have no doubt that this will be possible in the near future, even if not quite possible today. As a result, the bigger question might be at what point of accuracy for creating digital rules, broader digital regulation becomes viable to fully embrace. This may instead direct us toward the question of what value can ultimately be achieved from digital rules, what capabilities can this unlock, and taking your initiative further into the benefit side of the equation. The decision of which direction to go next might ultimately depend on stakeholders for your initiative and what they are most keen to learn about. Either way, the findings will be extremely valuable and continue to push forward the global financial services industry’s understanding of what’s possible from embracing data and digital advances. We look forward to seeing where your work goes next as we continue to pursue a digital vision for financial services regulation across the Atlantic.