Response to IOSCO Consultation on Use of AI and Machine Learning by Market Intermediaries and Asset Managers (FTAHK & LITE Lab@HKU)

In October 2020, the FinTech Association of Hong Kong and LITE Lab@HKU submitted a joint written response to the International Organization of Securities Commission (IOSCO)'s public consultation on the use of artificial intelligence (AI) and machine learning (ML) by market intermediaries and asset managers. The response strongly agrees with IOSCO that the use of AI and ML by market intermediaries and asset management firms creates novel opportunities and risks, with an overall need to foster trust in AI and financial markets. The risks should be appropriately mitigated by proportionate regulation that fosters responsible innovation and promotes market integrity, fairness and investor protection, financial stability, competition and innovation. It should also support financial inclusion and combat financial crime. The response draws attention to four important themes: (1) Encouraging the use of AI/ML in RegTech; (2) Addressing unintended consequences that may discourage innovation; (3) Guidance on Proportionality Factors (especially for Customer and Client Disclosure); and (4) Human-In-The-Loop approach to address AI fairness, accountability and transparency.  The joint response can be accessed here.