Prove It: Global — Reference Edition

Four examiners asked why the same concentration limit was approved

The general counsel faced FCA, FDIC, BaFin, and APRA examiners on the same Thursday across London, New York, Frankfurt, and Sydney. The institution had filed 43 regulatory documents in the prior 18 months and still could not produce the rationale in under an hour.

• FCA asked at 9 a.m. London time; FDIC at 2 p.m. New York; BaFin at the same time in Frankfurt; APRA at 8 a.m. Sydney, already Friday.
• The failure was architectural: separate jurisdictional records existed, but none answered "Why this limit?"
• The same decision had UK board minutes, a New York risk committee summary, a Frankfurt translation, and a Sydney board paper.

The paper treats global governance as one documentation problem

The paper argues that multinationals do not need separate decision-record systems for each regime. They need one record that explains what was decided, who decided, under what authority, why, and with what information.

• The surface language differs: SM&CR says "reasonable steps," CPS 230 says "documented rationale," FAR asks whether the accountable person understood the decision.
• DORA requires ICT decisions to trace to a management body with documented authority.
• The DA answer is a 17-field record built from cross-regime convergence rather than one jurisdiction's template.

Sixteen regulatory bodies converged at alpha = 0.91

The paper reports Krippendorff's alpha of 0.91 across 16 independent regulatory regimes when coding what a material decision record requires.

• Bodies named: FCA, APRA, BaFin, MAS, FSC, SEBI, FinCEN, CSRC, SAMA, OCC, OSFI, DFSA, King Committee, FATF, OHADA, and BCB.
• The paper uses this coefficient to argue that the 17 fields are empirical requirements, not a consultant checklist.
• Every jurisdiction covered requires RATIONALE, WHO identification to a named individual, and AUTHORITY documentation.

The superset record is DORA plus SM&CR plus FAR plus MiC plus CPS 230

The paper's implementation rule is to build one record to the strictest combined standard. A record that satisfies those demanding regimes also covers the other jurisdictions in scope.

• SM&CR makes the United Kingdom central because it is the most developed personal accountability framework in the paper.
• The UK standard, combined with Consumer Duty and DORA dependencies, covers approximately 60% of the remaining jurisdictions without further effort.
• Australia is described as the second-most demanding jurisdiction because FAR links individual deferred remuneration to accountability outcomes.

DECISION must record the actual operational choice

The DECISION field asks what was decided. The paper rejects records that only say a topic was discussed or a strategy was considered.

• Paper example: approve transfer of API manufacturing for Compound XR-7 from Dublin Site B to Hyderabad Facility 3.
• The record includes timing: effective Q3 2026, with dual-site production maintained through Q1 2027.
• The paper's bad version is "Discussed manufacturing strategy for XR-7."

WHO names a person, not a committee

The WHO field identifies the natural person who made the decision by name, title, and reporting line. Committee endorsement is not enough.

• Paper example: Dr. Sarah Chen, Chief Operating Officer, reporting to the CEO.
• The Investment Committee endorsed the manufacturing transfer, but Dr. Chen held the authority.
• SM&CR, Hong Kong MiC, FAR, and the EU AI Act all move accountability toward identifiable individuals.

AUTHORITY ties the decision to a delegated power

The AUTHORITY field records the legal, regulatory, or organizational basis that allowed the decision-maker to act.

• Paper example: Board Resolution 2024-017, approved 15 March 2024.
• That resolution delegates operational decisions up to $50 million in annual impact to the COO.
• The field can cite delegated authority frameworks, board resolutions, statutory mandates, powers of attorney, or regulatory licenses.

The paper separates required, recommended, and rewarded fields

maps all 16 DA fields against all 25 jurisdictions. The matrix is designed to answer whether each field is legally required, recommended by practice, or rewarded by sophisticated examiners.

• The paper states that every jurisdiction covered requires RATIONALE.
• Every jurisdiction also requires WHO identification to a named individual and AUTHORITY documentation.
• The three universal fields satisfy the core evidentiary requirement in approximately 20 of the 25 jurisdictions.

The same record must survive local differences in enforcement culture

The paper does not claim all regimes use the same words. It argues that the DA WHY field can satisfy different examiner expectations by requiring specificity, evidence citation, and individual attribution.

• FCA expects a reasoning chain a reasonable senior manager would have followed.
• APRA expects written documentation of the risk assessment behind the decision.
• BaFin expects evidence of management-body deliberation; MiC expects evidence that the named accountable person was genuinely involved.

Retention and privilege are design choices made at record creation

The paper treats GDPR deletion, SOX retention, and privilege variation as system architecture issues. The answer is not to choose one regime, but to build records with authority, retention, integrity, and privilege handling from the start.

• addresses conflicts such as EU deletion duties and US seven-year SOX retention.
• says privilege must be asserted when the record is created, not reconstructed later.
• The architecture separates Track 1 operational records producible to regulators from Track 2 potentially privileged records available only through legal review.

Volume I defines the framework; Volume II runs the program

The paper divides the work between a durable framework volume and an updateable implementation volume.

• Volume I has 31 chapters covering the 17 fields, jurisdiction mapping, cross-border issues, operations, and the Digital Companion.
• Volume II contains templates, workflow specifications, case studies, dispute playbooks, and examination preparation.
• provides quarterly regulatory update bulletins, downloadable field-specific templates, and practitioner alerts.

Additive compliance produced four answers and no rationale

The paper's central teaching point is that separate compliance programs create fragmented evidence. Decision Accounting replaces jurisdiction-by-jurisdiction documentation with one decision record built to the strictest combined standard.

• The GC's institution had built 15 compliance programs, each with its own record format, retention schedule, privilege doctrine, and definition of a documentable decision.
• The concentration-limit case shows the cost: records existed, but the reasoning chain did not.
• After moving to the superset standard, the GC answered the four examiners before lunch the following year.