by Alan McIntyre, Senior BA & Industry Relations Lead
In the good old days, it was the conferences with excessive hospitality – or rather excessive indulgence in that hospitality – that were likely to have a calamitous impact on an attendee’s ongoing employment. I recall a former colleague’s near infamous antics at a conference in a five star hotel in Florida (no my technical team didn’t rank an invite – sigh…). Well unfortunately for that ex-colleague, the allure of poolside daytime drinking resulting in – shall we say – overly gregarious antics at the formal event that same night did not impress his senior management much at all. He was sent home and dismissed as a result. [It didn’t end too badly in the long run as he found his calling in Sales!].
These days, it’s another type of conference that seems to be putting our industry’s jobs on the line. I’m talking about the so-called ‘disruptive’ ones which look at the replacement or automation of certain roles. I attended one such conference very recently where the topic under exploration was whether regulators such as the FCA could publish machine readable regulations. The conference was part of the UK financial regulator’s “call for input on the use of technology to achieve smarter reporting”. As someone who earns a large part of their livelihood as a Business Analyst reading regulations, interpreting them and then helping my clients implement them – this should send a shiver down my spine. It doesn’t though.
The conference was immaculately hosted last month at Burgess Salmon’s impressive Bristol offices, in partnership with Grant Thornton. It was well attended, by a wide spectrum of industry participants, including but not limited to regulated firms, consultancies and technology vendors like myself. Attendees were split into roundtable groups where we had the opportunity to discuss the advantages and challenges of turning lengthy PDF documents with codified regulations into formats that could be consumed by a machine. The underlying assumption is of course that machine-readable regulations would mitigate human error and interpretive differences that occur when individuals at different firms are tasked with translating the regulatory texts into business requirements.
It was a fascinating day and kudos to the FCA for their forward thinking in exploring these topics and launching such an initiative. At RegTek Solutions we are extremely aware that the current costs of keeping up with all regulations is untenably high. This is the exact reason why we’ve put helping our clients achieve sustainable compliance at the heart of our mission. We’re also big advocates of the advantages of mutualising the overhead of interpreting those regulations and converting them into controls. After all there is no competitive advantage in being the best at reading regulations. Although conversely there is a very real downside in being particularly bad at it with the risk of fines or regulatory censure. But gaining from being part of a community that’s interpreting and discussing the regulations is simple common sense to us as it helps avoid those human errors and highlights variations of interpretation.
So why then am I not losing sleep at the prospect of machine readable regulations replacing my role as the regulatory guy?
Well for starter this impressive initiative from the FCA and similar ones in other countries, including the CFTC’s ‘LabCFTC’ in the US and Singapores MAS ‘Regulatory Sandbox’, are all going to take a while before they arrive at anything tangible enough to fully replace reading those dreaded laborious PDFs.
Secondly, in my view, machine readable regulations would simply move the needle. Getting regulations published in codified form that could be automatically consumed is just a first step. Work will then be needed to build the machines capable of digesting the regulations (£-ka-ching ka-ching) and then transpose those machine-read regulations into the data models and system architectures of the various firms ($ka-ching ka-ching!)
I’m therefore not too worried. It’s certainly an interesting development on the journey, but it’s not the final destination by any means.
I can’t stop my mind from pivoting to ISDA’s CDM project, as I originally commented on here. Machine readable regulations will certainly reduce the scope for interpretive errors and omissions, but those machine digested business requirements will still need to be mapped to each firm’s data models and subsequently their processes and events model. Advancements in the CDM events model and data taxonomies such as ISO20022 will massively help with standardization. But this will all take time and effort as well.
Which brings me full circle to what prompted this blog. Well the FCA hosted another Tech Sprint on this topic last week. This time, rather than getting to enjoy the brief escape from London that the pleasant journey to Bristol offered, the conference was about half a mile and less than ten minutes on foot from RegTek’s office in the City. I registered online and received a nice ‘Personal Invitation’ email. However, due to a demanding day I only gave a cursory glance over and then filed away. Come the day of the conference, I checked the email to confirm my understanding of the location and itinerary. At the bottom of the email I spotted for the first time, “Click here to confirm your attendance”.
I clicked on the link with very low expectations and wasn’t the least bit surprised to read: “Sorry but this event has reached capacity”. Why am I outing myself for such an embarrassing mistake and my missing out on what would have no doubt been a great conference? Well the irony is just too great. Had a machine read that ‘Personal Invitation’ email, then no human error, interpretive or just plain bozo would have occurred. And there’s the rub. We’re prone to good old human error and this is impacted by circumstance. A hectic day led to my missing the key part of the emails text. A machine would not have made the same mistake. Meantime I guess I can look forward to the next FCA Tech Sprint on this. Though I might ask someone to doublecheck my booking!
Postscript note to my boss: I don’t suppose there’s budget for me getting an AI assistant? 😊
The views and opinions expressed in this article are those of the authors and do not
necessarily reflect the official policy or position of the company.