BRDA Living Data · Adoption Lag
Domain First Appearance & Adoption Lag
When climate risk first appeared in Basel publications in 2018, how long did it take the OCC, Fed, and FDIC to follow? This panel tracks the first quarter each agency mentioned each of the 20 policy domains and measures the lag in quarters between pioneers and followers.
Key Findings
- OCC leads on most domains — first to write about 13 of 20 topics, reflecting the breadth of its interpretive letter corpus (1989–present)
- Climate risk arrived late — first mention in Basel 2018, now covered by all 11 agencies
- International agencies lag domestic ones — PRA, BCBS, OSFI entered later (mean lag 87–97 quarters) because their text corpus coverage starts in the 2010s
- Crypto/digital assets — OCC was the first US agency (1996), but the modern treatment begins post-2018
Adoption Lag by Agency
Mean lag (in quarters) between the pioneer agency and each follower, across all domains where the agency was not the first:
| Agency | Mean Lag | Max Lag | Domains |
|---|---|---|---|
| Mixed | 21.6 Q | 49 Q | 9 |
| OCC | 30.2 Q | 67 Q | 13 |
| FDIC | 47.5 Q | 98 Q | 11 |
| FFIEC | 57.8 Q | 62 Q | 6 |
| CFPB | 70.0 Q | 71 Q | 2 |
| PRA | 87.1 Q | 137 Q | 18 |
| BCBS | 88.4 Q | 109 Q | 17 |
| CSBS | 93.7 Q | 121 Q | 18 |
| OSFI | 97.1 Q | 133 Q | 17 |
| Fed | 105.6 Q | 145 Q | 15 |
White Paper: Regulatory Contagion & Diffusion
Does supervisory attention on new risks propagate like a contagion — or do agencies discover them independently? This panel enables event-study designs around domain first-appearance dates. Pair with the international panel to measure whether Basel publications predict domestic agency attention shifts, and whether enforcement actions follow attention with a predictable lag.
Applications: Regulatory propagation speed estimation, leading indicator identification, supervisory coordination measurement, emerging risk detection