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Machine learning in UK financial services (bankofengland.co.uk)
139 points by goatinaboat on Oct 18, 2019 | hide | past | favorite | 71 comments



Thanks for sharing. Was literally just reading it a few minutes ago with great intrigue. Would be interesting to see what is classified as real ML and how much of it is being used for actual decision making - I lead an ML team at a bank and everyone tries to sell it more than it is.

Fraud detection is one of the areas I've come across that are actually doing something interesting within retail banking. But agreed - plenty of opportunities for ML to make things more efficient.


A a paraphrase of a kind of self-deprecating but insightful comment from a ML prof I heard: There’s a lot of hype around machine learning, but it can’t really do that much. If you want to see what it’s capable of, check your Amazon recommendations. Sort of works some of the time, and other times offers you complete nonsense. Amazon has very smart engineers and the best algorithms and tons of data. This is about the limit of what you can currently do.


Watching the UK try to adopt ML is like watching a toddler try to drive a Ferrari.

The BoE prides itself on being "up" with the latest talking points amongst the chattering classes. But take a look at how the BoE is actually run and you will get an idea why British society struggles with change.

Incompetence and knowledge of irrelevant information is pride of place in British society. Example: Carney has been the most accident prone BoE governor since...the last one, who was trying to raise rates in 2008...the Chief Economist was head of Financial Stability in 2006...yes, seriously (incidentally, he recovered his reputation by being able to hit headlines by talking about new trendy topics like ML).

Where ML has been implemented in the UK it is often by managers who have almost no competence in any real-world skills. They have heard about ML, think it is magic, and want to look like they know what they are doing. This has resulted in very bad outcomes (a recent story - https://www.theguardian.com/society/2019/oct/15/councils-usi...).

I don't think this effect is at all well understood (economists, for example, tend to assume that the person in charge actually knows what they are doing...despite all the research suggesting the contrary in the UK). Insurance has done well because there is a good level of statistical knowledge amongst managers. But I suspect the UK will continue to lag the world (as it does in almost everything else) as the hype disappears, and the typical British suspicion of new technology and change returns.


I work in a corporate and am constantly amazed how much currency buzz words seem to have. We got a new CEO who is into "tech" and different directors are fighting to deploy poorly though out AI and VR projects. It has little benefit to the business but it helps people sell themselves within the company.


After working on a completely failed project in a non-software department of a large organization, I’ve realized that (depending where you are) the main deliverable for a lot of things is what your manager can put in his power point presentation to his manager.

Of course if the project lasts long enough the software being reasonably good starts to matter as you start finding out things you promised people don’t work anymore, your huge rats nest of code makes it too hard to add features like, etc. But until it hits the “power point bottom line” a non technically educated manager will not care at all.


Interesting to see that insurance is ahead in adoption, compared to capital markets, where I work. Suspect that the tree based models reported as popular are used for underwriting decision making. We sales & trading capital markets people tend to see insurance as the sleepy backwater of wholesale capital; just cash cow real money funds to be gouged by sharp market makers to put it bluntly.


Why is this? Insurance providers actually provide a valuable service (not necessarily implying that much of the enormous UK financial industry does not...) and is profitable and sustainable; I am surprised to hear it described as something to be "gouged". How would such a gouging occur?


Market making dealers in govt bonds provide liquidity to different types of fund managers. For instance, hedge funds, insurance funds, pension funds. All fund managers must preserve and/or grow funds. Pension and insurance funds are referred to as "real money" as, unlike hedge funds, they don't use broker dealer credit to leverage positions. They are also highly regulated compared to hedge funds, so can't use derivatives, go short or generally pursue riskier strategies. So regulation prioritises capital preservation over growth, for obvious reasons. Real money funds tend to be far less technically sophisticated than HFT or systematic trading hedge funds. So they get charged more, in the form of wider spreads, by dealers as they go in and out of positions. Why might they go in and out of positions? One reason would be tracking a govt bond index monthly. The bonds in the index may change, so to continue tracking a real money trader has to buy some bonds and sell others once a month. That real money trader will get a worse price from the dealer than a hedge fund trader who has far more live market data and pricing tech to assess the prices offered by dealers.


It's worth noting that traditionally, actual insurance runs at a loss or break-even, most of the profits tend to come from investment.

This has changed recently, as investment returns have dropped, and may also be driving the adoption of better statistical techniques for modelling risk (as they can't rely on investment income to make up for insurance losses).

Also, having read this report, I'm very very sceptical about whether or not companies are using "ML". I suspect that most of them are just doing linear/logistic regression on larger data sizes, which isn't really the same.


If the linear / logistic regression stuff is improved through Bayesian methods and hierarchical modeling, and if it grows large enough that there is a need to use MCMC sampling techniques for approximate posterior inference, then even though the model specification itself would be very simple, I’d absolutely say this is “ML”.


I really, really wouldn't. That's Andrew Gelman's gig, and he's been doing that since the 80's, when ML/AI was all about expert systems. I think of that as a statistical technique, not an ML one (and for some weird reason, many quantitative people in insurance don't like Bayesian techniques).

But then, our disagreement here just highlights the difficulties involved in getting consensus on what ml vs statistics actually are.


I think I have settled for ML = gets better with more examples ("learns"). So I'd say Bayesian models of all flavours are definitely in the ML umbrella. AI is super fuzzy though. I think of that as, does something you'd think a computer shouldn't be able to do but a human can, and is thus a forever moving goalpost.


I probably wouldn't use that definition, as all statistical techniques will improve as the number of examples increase (i.e. the estimate will be more precise). If you mean that ML normally estimates more parameters, and as such improves more with more examples, I would agree, but it's very difficult to draw a dividing line then (what about splines - loads of parameters, very flexible, but not normally classified as an ML technique).


Depending on how you look at "improvement", that's not strictly true. Often, large data sources are slightly biased relative to the population we want to generalize to (say, a single regional company's customers, trying to generalize to a national population). Working with larger and larger such data sets, that bias can become large relative to standard errors/credible interval width.

Xiao-Li Meng has had some interesting talks/papers about this and related ideas: https://dash.harvard.edu/handle/1/10886849


I was never convinced by that paper, to be honest. I almost always use MLE so that's not really an issue. It just struck me as a pedantic distinction without a difference.

But if you use GEE, it's probably great to know.


That applies to ML techniques also, mutatis mutandis.


Splines are totally ML if gaussian processes or markov random fields are ML... Also, not saying that I agree with the definition or any sensible cut between statistics and ML, just my mental model for interpretation of what people are talking about when they talk about ML


> I think of that as a statistical technique, not an ML one

Many ML techniques are statistical techniques, not ML. If we go down this road.


I completely agree, and have been banging this drum for years :)


There is a real risk of venturing into narcissism of small differences with this.


Like, personally, I regard statistics and machine learning as the same subject from different perspectives (mathematics vs computer science). Their differences are primarily driven by the context of the time of their development. Back when we had very little data, we needed strong assumptions to make inferences. As compute increased, this became less necessary and we could just bootstrap instead of needing normal theory confidence intervals.

But apparently, this is a controversial view.


> I think of that as a statistical technique, not an ML one

Perhaps not all, but most of the distinctions between "statistical" techniques and "ML" techniques are fairly arbitrary.


And do we care if they do the job?

Especially if they share the same trait of being so complex and dependent on Byzantine treatment of data that they need to be regulated and governed in a different way from something that can be groked via a single ppt slide?

edited for the second clause.


Machine learning is a superset of all of statistics.


I would probably have said the opposite. Can you clarify why you think the scope of ML is greater than that of statistics?


Rule based systems


OK, but I guess I could argue that asymptotic theory and design of experiments are proof that statistics is a super-set of ML (for the record, I'm not sure either of those is true).


> It's worth noting that traditionally, actual insurance runs at a loss or break-even, most of the profits tend to come from investment.

I hadn’t considered that. It sounds like another reason why insurance is broken. If you have two options, $100 premiums and $100 cost; versus $1000 premiums and $1000 cost; the net gain on premiums vs cost is the same, but the investment income over the interim will be higher when the total amount of money in the system is higher.

I would be interested to see the average premium price compared to total investment funds across different geographies and times


That's been one of the supposed consequences of the 80/20 rule that Obamacare introduced, although I can't find any numbers, just speculation that insurers are doing it. The 80/20 rule says that the insurance companies must spend at least 80% of their revenue on actual health care, or else they have to return money to the insured. So if you're a healthcare company and your stockholders want to see increases in profit, the only way is to spend more money whether it's necessary or not. You can't make more by increasing efficiency.

Searching for this gives articles about how the insurance companies actually have returned a fair bit of money, and none with hard numbers about this actually driving healthcare costs up, But there could be a lot of reasons other than "it hasn't driven costs up" for why it's not showing up in a quick search.


Yeah that was my take-home message too. Seems like plenty of opportunities for ML here.


The key takeaway from this for me is that there is no shortage of machine learning practitioners in the UK despite popular opinion that it is a good career move


Where I am at the moment, a UK bank's retail data analysis service, any ML projects are set up on a "learn as you go" basis whilst still doing your main job. No specialised practitioners are deemed required.

Whether or not this is a good idea is moot: this is in the bowels of the bank and not the bleeding edge of commerce.


We don't really need specific ML practitioners for most jobs in the same way we don't need Genetic Algorithm practitioners in most jobs either, unless you're a researcher you can just read a book about it and start trying it out.


It is more like do you specialist x, eg if you have fullstack engineer do you really need frontend developer or DevOps engineer, generally no but there is case where specialist might make big differences.


fullstack engineer do you really need frontend developer

These terms are meaningless in both ML and finance.


I read it as an analogy, I think that's what was intended.


this seems deeply misguided.. the phrase "its all good" comes to mind, which is common, but meant to be comforting, not factual. This comment makes no distinction within the world of software, between architecture, experiment design, experiment interpretation, accurate input, accurate/effective team participation, reporting and communications, and more .. To day "read a book" then "do it" is a nice thought, certainly. The lack of self-awareness about what it is to build skill, and the lack of acuity to see what is effective practice versus say, noise.. hm

Perhaps, vetted and peer-reviewed on the one hand, and person on the commute bus with a pop-topic book on the other.. there has to be some awareness of that spectrum. With no indication of that awareness here, it just does not bode well.


You are talking about how you wish it was, but the comment you are replying to is merely stating how it actually is.


Indeed. If you already understand the data and the business and you already know Python or R then you can download Keras in the morning and have something useful to the business running in the afternoon. Then you can add ML to your CV.

It’s not clear where an ML expert who isn’t already familiar with the data and the business fits in or adds value, or even what an expert really means in industry.


Domain knowledge is really important, you can't overstate that.

But you've also succinctly described why a huge percentage of ML as practiced in industry under performs or flat out fails. To a first approximation the person who reads a few tutorials and plays with example data sets, then sets out to apply it to their own domain, has no real idea what they are doing - and it shows.


Adding ML to your CV with the Mickey Mouse experience and understanding you describe would be a good way to get yourself drummed out of a job where you are actually expected to have the expertise you claim.

Agree with your point about domain knowledge being important.


This comes down to how well your ML-leading exec is at articulating the business value of the project and coming up with a strategic roadmap to go from "learn as you go" to fully embedded while managing risk.


Indeed. The Bank of England's report was summarised by one news source yesterday as "Banks say there's no shortage of machine learning talent"[0].

[0] https://news.efinancialcareers.com/uk-en/3002418/machine-lea...


Absolutely true.

I have several friends who are machine learning practitioners. Many are actively looking to get out. When you strip away the hype and BS the demand in London is very thin.


In my experience, this is usually because they realise that applying sexy algorithms and generating magic earth-shattering insights is about 2% of the job, and the rest is "boring" stuff like automation, data cleansing, performance at scale, and building and maintaining discipline around sound development practices.

Edited to add: this isn't a diss on them or this phenomenon in general -- it keeps me employed :)


There are likely very specific areas where ML can have a real impact and other areas that are nice, interesting but not really priority.

From my experience, a large part of the demand also needs to be driven by the AI and ML execs' ability to sell to the business.


If you have deep domain knowledge already then ML skills are the icing on the cake. But opportunities for those with just the ML part are minimal.


Agreed - many folks discount deep domain knowledge which is, my opinion, a mistake.


It just tells me that senior banking people in the UK have such a shortage of senior ML people that all they see is mickey mouse ML stuff by shysters and snake oilers. They would have to do real work on the antique back end to make it work, and that is hard.


I don't quite see how you can come to that conclusion. The report is only about companies that responded to the survey: "The survey asked firms to provide information on two ML case studies within their organisation." Any company that doesn't have two ML case studies to talk about isn't included. That might be 10% of finance companies or it might be 90%. We can't know from what's in the report.


Charts 11 and 12 show that lack of talent is a minor consideration. I would be willing to bet that most people would have expected it to be much higher.


Self selected for firms who have big enough teams to respond to the study. Bias.


It's hard not to be cynical reading these discussions. Avoiding plastic or recycling it does near zero for the environment. Reducing travelling, reducing goods consumption, reducing construction, reusing things and protecting land are the real effective solutions but require sacrifice. Yet people refuse to go beyond performing ridiculous plastic straw theatre.


Is this comment supposed to be attached to "machine learning in uk financial services"?


No. I'm sorry. I don't know what happened.


Well this is not the way. We don't want or need to improve environment by 'reducing travel, consumption or construction' i.e. destroying the economy and going back to stone age. Goal is to optimize resource use to improve environment while INCREASING all of that steadily.


Hypothetically, if you had to choose, which would you choose — the economy or the environment?


Those aren't mutually exclusive.


Learn to read.


Of course economy. Environment is just one of the externalities. Also, environmental issues are mostly just a pretext for geopolitics right? Say, real deal about global warming isn't saving some turtles or some Pacific islands from sinking, but crippling bad guys such as Russians and Arabs who export oil, right? It's a way of putting liberals, unknowable to them, in the same directions as conservatives are.


Ah, glad to know you think global warming is solely a partisan issue.


Not at all. I believe in reality of global warming. But, political reality is different from physical reality: it exists in political reality and in public perception only for the reasons i cited. Otherwise, ofc it would still exist, but we wouldn't know or care.


My frank opinion as someone ~2 years into grad school in something to do with computers and statistical inference (taken a bunch of numerical classes, ML courses, maybe ~1 year of grad level stats coursework): if you actually want to do statistical analysis for a living, you need get a statistics degree. CS people are irrelevant except for computational issues. As a CS guy probably you can be useful for scaling a system to do automated inference, or as an advanced database guy, or writing shell scripts or something.

If you go to grad school in CS and work hard in the right subfield you might develop the understanding of someone with part of a stats BS. Again, the part you would actually know something about is computation, which as far as I can tell isn’t a real bottleneck for anything except very large automated systems. Otherwise some guy can just use R and his laptop.

I mentioned my status above because this is solely based on me evaluating things in an academic setting and not job experience, but this seems very clear to me once laid out like above.

ML is “hot” but it seems to me like an extraordinarily specialized area of expertise with little general applicability.


agree but -- previous eras of statistics used important and non-obvious ways to infer from subsets of data.. now, whole sets are used, and the subset part is more like a representation problem. Second, the things that are made to be important in school, are not always important outside of school. You do acknowledge that tacitly there..

The point of view in the post here is from an individual, regarding the work of another (hypothetical) individual, while the paper linked spends quite a lot of effort to characterize in the real world, real activity by large and very large, organizations, mainly business, and mainly the business of money.

You conclude that the field has "little general applicability" and that might be true in some sense.. but large organizations, and particularly large finance organizations, are not general at all, but rather composed of a very large number of specialized and repetitive operations.. exactly what ML and AI perform, no?


My understanding of the history of the stock market is that it was nothing short of a revolution in the sense that "normal people" suddenly could invest in large companies, and that these new types of publicly traded companies through the power of what we today would call "crowdsourcing" managed to bypass the old giants through their accountability to their shareholders and their ability to raise capital from the masses. So far, so (pretty) good.

Next, I'm reminded of when Elon Musk talked about integrated AI, and how we may one day end up in a situation where any type of intellectual or physical competition between humans, in the labor market or elsewhere, may just come down to how much money they have to spend on cybernetic, biological enhancement products.

My synthesis here is that from my perspective, the stock market has since the advent of digital trading tools, now vastly accelerated by expanded usage of machine learning in financial markets, completely undermined the original benefit of the stock market, where a pretty true democratization of the economy, almost an incredibly true one considering it was born in a capitalist society, has now been rolled back and undermined by "big capital" finding a tool that allows them to rig the game to their favor.

So if the assumption is correct that machine learning in financial markets essentially is just an interface for the already-rich to beat the never-rich by throwing more money at the problem, doesn't it stand to reason that these types of tools should be heavily regulated, if we want a stock market that has any resemblance of fairness and democratic influence on the economy?

I understand very well we are far away from this today, and I understand that rich people will not allow regulations that punish them, but if we go beyond the knee-jerk reaction of "cash rules baby", is this really the way things should be?


There are two big assumptions in your hypothesis that are incorrect in my opinion:

1. The prevalence if machine learning in trading. 2. That the game wasn't rigged against retail at a point in the past.

First, there is very little (almost none) sophisticated ML in trading. Sure, if you call linear regression or simple classification tools ML, then yes, there's plenty of ML in finance, and has been for decades. If you think that there are super sophisticated DNNs running the majority of trading today, you are very far from the truth. The vast majority of trading is based on fairly simple models. It happens mostly based on human insight and exploiting specific market flows. Sure, almost every firm has some token ML overlay for marketing purposes because it was the fad of the recent years. They all want the public to think that they have some super secret sophisticated AI that gives then an edge. It's all a smoke screen. Almost none of them mean it in earnest. In truth, it is incredibly difficult to build anything resembling a scalable and robust strategy with complex ML tools. The reasons are too numerous to describe here. a very small handful of firms have the capability and mandate to actually use these tools with success, but their market participation is minute, basically negligible.

Second, the game was always rigged in a sense. Big money could always buy privileged access to liquidity, information and tools. Nothing has changed here. If anything, the commoditization of all three of those things has lowered the barrier of entry. You can run a successful quant fund with a couple of friends now. That was much more difficult before.


There is a tremendous book called "Where are all the customers' yachts?" on how the middlemen used to be the people making all the money: https://www.amazon.co.uk/Customers-Yachts-Street-Investment-...

Very rarely have individual investors from the "masses" done well out of the markets. If they did, they were usually upper-middle-class to start with. Until the 80s and the internet age there were distinct barriers to entry. What did happen was fund investment, at one remove - especially pensions, but also products like life assurance and annuities. The funds are one of the groups deploying machine learning now.

> if we want a stock market that has any resemblance of fairness and democratic influence on the economy?

I'm not sure that's the correct place to deploy the fairness levers against overall economic inequality. We come back to the need for a wealth tax to address dangerously large concentrations of capital destabilising the economy like cargo shifting in a plane.


There are benefits of scale, sure. But it's basically the same for other aspects. The rich can buy better education, invest in hobbies etc while the poor can't. So it's nothing new and i think because "AI" tools are getting so widespread it will actually offer better options for the poor. Same with free education tools getting more and more popular. So it's not all negative.

But when speaking about very advanced tools that could, in theory, give unprecedented advantage to few rich people it would be in the best interest of governments to invent tax schemes that would redistribute their earnings more evenly. On the same note i think countries ought to implement digital taxes in the near future to not to become digital colonies where the internet companies have no employees and pay their taxes elsewhere, eg ireland. With margins as high as they are for digital goods where it's all ones and zeros traveling through cables, to support their own economy and skilled workforce something has to be done.

It's already a problem where the rich can make their money in some country but pay their taxes to tax havens. When the companies can employ the same thing without even investing anything in the countries they are operating it seems the playground is uneven for a lot of poorer players.


Tim Harford in "The Undercover Economist" has a neat description of how the market isn't rational and really can't be predictable. So I'm not worried about machines in the market as they can't really do any better, I believe.

As for the super-rich, they have asset managers who pool family funds. Even a small family fund will have millions invested and a small asset manager will have billions under management (pick your own major currency). Every millionaire will be doing the same thing so none of them get an advantage and going against the herd would be unlikely to pay off, short to mid-term (again, my reading of "The Undercover Economist").


Thanks for sharing ;)

Of interest as well may be London Fintech week July 4 2020

https://www.fintechweek.com/


Maybe before we rush to adopt machine learning in financial services we should consider the consequences of blithely giving this technology such a central position in our lives.




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