Manifesto
activeRegulator as Design Partner
Regulation is used as a shield far more than it is used as a constraint. Stop treating the regulator as the enemy.
organisational fluencyregulationfinancial servicescompliance
Almost no banks have proactively gone to the FCA or the Fed and said: here is what we want to change, here is why it is better for customers, here is how we will demonstrate it. The reason is that the people who benefit from regulatory complexity are inside the institution. Compliance teams, legal teams, risk teams. Their institutional power derives partly from the opacity of the regulatory framework. Simplification threatens them.
Key claims
- 1A bank that went to the regulator and said here is our data architecture, here is how we can give you real-time visibility, here is how technology actually improves your oversight, that bank owns the conversation.
- 2Compliance is built on legacy systems reporting in formats designed in 1987, and everyone calls it a regulatory constraint when it is actually a technology failure nobody has the mandate to fix.
- 3The regulator conversation is not a tactical fix. It is a signal about whether leadership has the will to take on internal vested interests, not just external ones.
Tensions
- The people who benefit from regulatory complexity are inside the institution. Simplification threatens the people you need to execute it.
- Proactive regulatory engagement requires a level of technological literacy and institutional confidence that most boards do not have.