Question
Should the United States adopt a federal regulatory sandbox modeled on the UK Financial Conduct Authority's program?
FAME's position
The UK Financial Conduct Authority sandbox — the world's first and most-studied — is associated in the empirical record with a statistically significant decline in digital-bank performance across every standard metric (net interest margin, ROA, ROE, yield on earning assets), robust to controls; the mechanism appears to be increased compliance and operational costs from bespoke supervisory arrangements, not the lighter-touch regulation sandboxes are typically marketed on. The harm is concentrated in larger, more mature, and state-owned institutions — the firms whose advocacy most often drives sandbox adoption — while only the youngest, smallest firms show positive coefficients. The institute therefore does not support general-purpose federal sandbox programs marketed as innovation accelerators. It supports, at most, narrowly scoped programs limited to genuinely novel business models facing real regulatory ambiguity (not established models seeking lighter ongoing supervision), with mandatory publication of structured post-program performance data so the U.S. record is evaluable. On one published study of 24 UK firms, the institute's position is that more evidence should precede, not follow, federal adoption.
Evidence base
- — Washington, Rehman & Lee (2022), Nexus between Regulatory Sandbox and Performance of Digital Banks, JRFM (DOI 10.3390/jrfm15120610) — UK FCA panel of 24 digital banks (2016–2021) showing a statistically significant negative association between sandbox participation and all four performance metrics (NIM, ROA, ROE, YEA), with lag effects stronger than contemporaneous and harm concentrated in larger, more mature, and state-owned firms.
- — Forthcoming: U.S.-state sandbox programs replication study (Year 2)
Adopted 2026-05-08