Standard Setting Organizations Research Articles

Enhancing Regulatory Frameworks for Islamic Banking Institutions: Comparative Study Between Indonesia and Bahrain

This research analyzes and compares the regulatory frameworks governing Islamic Banking institutions in Bahrain, and Indonesia. The study explores how each country has developed its regulatory environment to support the growth and stability of Islamic finance, highlighting the successes, challenges, and areas for improvement. Using a qualitative comparative approach, the research draws on data from document analysis and previous studies to provide a comprehensive understanding of the regulatory landscapes in these countries. The findings reveal that Bahrain has established robust and internationally recognized regulatory frameworks, largely due to their proactive regulatory bodies and collaboration with global standard-setting organizations such as the Islamic Financial Services Board (IFSB) and the Accounting and Auditing Organization for Islamic Institutions (AAOIFI). In contrast, Indonesia, despite its significant potential, faces challenges in regulatory implementation and public literacy on Islamic finance. The study concludes that effective regulatory frameworks are crucial for the credibility and stability of Islamic finance, strengthening regulatory oversight, and adopting international standards to ensure consistent and transparent practices. This research contributes valuable insight for policymakers, regulators, and practitioners aiming to improve the regulatory environment of Islamic financial institutions globally.

Large language models (LLMs): Risks and policy implications

"Although statistical language modeling has been a fairly active area of academic research in artificial intelligence (AI) since the 1980s, the recent explosion of both technological innovation and public attention around LLMs has dramatically changed the space of applications for this work. The unprecedented scale of these new models carries with it emergent capabilities—particularly in the form of generative models—that have made the technology generalizable to a broad range of use cases and accessible to the general public. Yet these rapidly developing features also pose novel risks, ranging from environmental impacts and copyright violations to misinformation and hate speech. Traditional regulatory frameworks are not well-equipped to match either the rapid pace of innovation or the ability of LLMs to transcend the jurisdictions of individual governing bodies. Thus far, the governance gap has been filled by soft law frameworks such as private company standards, voluntary codes of conduct, and design guides from non-regulatory standard-setting organizations. Still, there is rising demand to solidify these soft guidelines into hard law. In addition to offering a historical overview of LLMs and highlighting some of the most pressing concerns involving LLMs today, we discuss legislative attempts to address these concerns and outline potential complicating factors."

Technology Coopetition and Voluntary Disclosures of Innovation

ABSTRACT We examine firms’ voluntary disclosures of innovation under technology coopetition, focusing on technology standard setting organizations (SSOs). Technology coopetition is characterized by (1) cooperation to determine technology standards, which requires information sharing to reach consensus, and (2) competition for standard implementation to obtain standard-essential patents, which create incentives for firms to deviate from the expected level of information sharing. We document a decrease in 10-K narrative R&D disclosures, more generic 10-K narrative R&D disclosures, and a longer delay of patent disclosures via the USPTO after a firm joins an SSO. Among alternative explanations, our evidence is most supportive of the hypothesis that firms strategically withhold innovation information. JEL Classifications: L15; M41; O32.

The Prospects of AfCFTA in Promoting Industrialization and Economic Diversification in Africa

African Continental Free Trade Area (AfCFTA) functions as a boost for Africa's economic development by enhancing intra-African trade. This is because trade is an engine of growth and development. For the fact that most African nations that are located within the same region engage in similar and competitive production, the ensuing economic cooperation and trade exchanges not only have the promise of increasing trade but also stimulating other ancillary economic activities, creating new job opportunities, speeding up economic growth, promote the standard of living, and promote economic development. However, AfCFTA's record has not been very impressive. The main obstacles to intra- regional commerce among African countries include heavy reliance on trade in primary goods, high product and market concentration of exports, and inadequate regional manufacturing networks. This study therefore examines continental economic trends and Intra African Trade: Prospects for African Continental Free Trade Area. The study adopted qualitative methods of data collection and analysis and the comparative theory of integration. The study found that the low level of trade diversification implicated the capacity of the African Continental Free Trade Area (AfCFTA) to achieve improved intra-regional trade performances in Africa. African countries maintain as much as 77% export specialization, with higher external/world trade at 84.6 percent of their total import and export trade. The study recommended that Governments should invest in infrastructure development, including building roads, railways, ports, and airports, as well as improving access to electricity and broadband. Governments should adopt modern trade facilitation measures such as electronic customs systems, single window platforms, and risk management techniques and should align their technical regulations and norms with global best practices and standards, as those created by appropriate international standard-setting organisations like the International Organisation for Standardisation (ISO).

Oversight of Dual-Use Research: What Role for Ethics Committees?

The World Health Organization (WHO) Global Guidance Framework for the Responsible Use of the Life Sciences addresses the governance of biorisks, including dual-use research, for countries. It emphasizes engaging multisectoral stakeholders such as governments, scientific bodies, health and research institutes, standard-setting organizations, funding bodies, and others. Ethics constitutes a key component of the framework. Given the high social impact of such research and the importance of trust, risk, and benefit, national ethics committees could make a valuable contribution by providing ethical guidance in the decisionmaking process. The purpose of this study was to examine the role of national ethics committees in the context of governance and oversight of dual-use research at the national level. We conducted a landscape analysis of the activities of ethics committees in dual-use research oversight. We also searched the WHO database on National Ethics Committees for publications related to dual-use research and/or misuse of life sciences research and gathered additional documentation from national ethics committees websites and through author contacts. Results showed that in the context of the wide range of oversight mechanisms for dual-use research in countries, national ethics committees have contributed to guiding policy and assessing dual-use research risks in only a limited number of countries. Recommendations from those countries include establishing a multistakeholder, coordinated oversight mechanism at the country level; strengthening international linkages to guide, harmonize, and reinforce national and international efforts; and involving ethics committees as an expert resource in the governance and oversight process.

Role of Standard Setting Organizations in the Indian Ict Sector: an Intellectual Property Law Analysis

Introduction: Standard-setting organizations (SSOs) are critical policy-making bodies that have a decisive bearing on technical sectors that are not just global, but also in Indian society. They form rules that become the reference point for stepping up the development and deployment of the tech. This study is designed to open the curtains and delve into SSOs' standard-setting process in the Indian ICT sector and assess the challenges that emerge. Objectives: The worldwide efficient methods employed by the global SSOs and contrast them with the Indian ones to spot correlations. Moreover, Indian SSOs' IPRs hidden under Indian patent laws will be also looked at. In the end, apart from the recommendations for upgrading and aligning the policies regarding the standardization of ICT equipment in India, we will also provide some suggestions. Theoretical Framework: The sequel of this process will be the exploration of IP laws such as patents in India focused solely on patent licensing - the standardization practice carried out by patentees. Results and Discussion: Emphasize the standard-setting actions of Indian SSOs by highlighting the problems encountered. A comparative analysis of substantive cooperation between inter-planetary and Indian anti-space security organizations will be carried out. Lectures covering how Indian SSOs match the Indian Patent Act and Rules will accordingly be given. The implications of the high effect of ICT standardization in India will be suggested. Considerable facts will be culled from doctrinal law, and each of the methods used in the licensing of education institutions will be examined. Research Implications: Improving standard-setting processes by key Indian SSOs such as BIS(Bureau of Indian Standards), ISRO (Indian Space Research Organisation) and ISIF (Indian Standards and Industrial Classification of All Economic Activities) Moreover, the Indian IP legal system and licensing structure will be proposed to ensure integration barriers are addressed and the standardization of the ICT is improved.

A Conceptual Study on Implications of Green Finance in India

Abstract: The financial industry can help reduce the risk of climate change and lessen the effects of unfavourable climate occurrences, which is a significant contribution to the battle against climate change. Maintaining financial stability and spreading climate-related risks can be aided by long-term institutional investors. Other financial tools, such as green stock indexes, green bonds, and voluntary de-carbonization programmes, can assist reallocate investment to "green" industries. Hedging products, such as catastrophe bonds and indexed insurance, help insure against increasing natural disaster risk. For the foreseeable future, climate change is expected to remain the central political and economic issue of this century. Globally, governments, corporations, investors, and private citizens are starting to act on climate change, particularly with regard to decarbonisation strategies. It would take exceptional amounts of new capital investment—green financing, in particular—to support the kinds of initiatives that reduce greenhouse gas emissions and help businesses adjust to the effects of climate change in order to transition to a low-carbon or green economy. For this reason, it's critical to comprehend what green finance is and why it matters. In order to handle the complex risks that climate change poses, central banks and other regulators are modifying their frameworks and procedures from an oversight standpoint. Among the strategies for enhancing climate risk disclosure and categorization requirements are those that will assist investors and financial institutions in evaluating their exposure to climate risk, as well as regulators in assessing systemic hazards. Supporting the development of climate-related stress tests and broader promotion of green finance, the IMF is collaborating with standard-setting organisations such as the Network of Central Banks and Supervisors for Greening the Financial System. The researcher concludes that it is important to pursue this investigation in light of the aforementioned facts

Three pathways for standardisation and ethical disclosure by default under the European union artificial intelligence act

Under its proposed Artificial Intelligence Act (‘AIA’), the European Union seeks to develop harmonised standards involving abstract normative concepts such transparency, fairness, and accountability. Applying such concepts inevitably requires answering hard normative questions. Considering this challenge, we argue that there are three possible pathways for future standardisation under the AIA. First, European standard-setting organisations (‘SSOs’) could answer hard normative questions themselves. This approach would raise concerns about its democratic legitimacy. Standardisation is a technical discourse and tends to exclude non-expert stakeholders and the public at large. Second, instead of passing their own normative judgments, SSOs could track the normative consensus they find available. By analysing the standard-setting history of one major SSO, we show that such consensus tracking has historically been its pathway of choice. If standardisation under the AIA took the same route, we demonstrate how this would lead to a false sense of safety as the process is not infallible. Consensus tracking would furthermore push the need to solve unavoidable normative problems down the line. Instead of regulators, AI developers and/or users could define what, for example, fairness requires. By the institutional design of its AIA, the European Commission would have essentially kicked the ‘AI Ethics’ can down the road. We thus suggest a third pathway which aims to avoid the pitfalls of the previous two: SSOs should create standards which require “ethical disclosure by default”. These standards will specify minimum technical testing, documentation, and public reporting requirements to shift ethical decision-making to local stakeholders and limit provider discretion in answering hard normative questions in the development of AI products and services. Our proposed pathway is about putting the right information in the hands of the people with the legitimacy to make complex normative decisions at a local, context-sensitive level.

Collaboration and social capital in meta-organisations: bonding or bridging?

ABSTRACT How do firms collaborate to achieve their strategic goals within inter-organisational settings? Inter-firm collaboration is a double-edge sword – it helps firms to obtain external resources, but it also increases risks of knowledge spillovers with competitors. Normally, spillover risks are reduced through formal contracting. However, meta-organisations, like standard-setting organisations, lack formal contracts, meaning that firms often rely on social capital to offset transaction costs and opportunism. This paper applies theories of social capital to explain inter-firm collaboration within the meta-organisational environment of 3GPP (Third Generational Partnership Project) – the primary global mobile telecommunications standard-setting organisation. It utilises a stochastic actor-based model and a comprehensive collaboration dataset from the 3G to 4G eras to examine the mechanism of collaboration. We find that firms are more likely to choose partner firms based on the ‘bonding’ view of social capital, rather than the ‘bridging’ view. The paper advances research on collaboration mechanism within meta-organisation, while also contributing to social capital theory in emphasising the importance of the bonding view of social capital under conditions when no formal contracts are available.

The effect of natural products used as pesticides on the soil microbiota: OECD 216 nitrogen transformation test fails to identify effects that were detected via q-PCR microbial abundance measurement.

Natural products present an environmentally attractive alternative to synthetic pesticides which have been implicated in the off-target effect. Currently, the assessment of pesticide toxicity on soil microorganisms relies on the OECD 216 N transformation assay (OECD stands for the Organisation Economic Co-operation and Development, which is a key international standard-setting organisation). We tested the hypotheses that (i) the OECD 216 assay fails to identify unacceptable effects of pesticides on soil microbiota compared to more advanced molecular and standardized tests, and (ii) the natural products tested (dihydrochalcone, isoflavone, aliphatic phenol, and spinosad) are less toxic to soil microbiota compared to a synthetic pesticide compound (3,5-dichloraniline). We determined the following in three different soils: (i) ammonium (NH4 +) and nitrate (NO3 -) soil concentrations, as dictated by the OECD 216 test, and (ii) the abundance of phylogenetically (bacteria and fungi) and functionally distinct microbial groups [ammonia-oxidizing archaea (AOA) and bacteria (AOB)] using quantitative polymerase chain reaction (q-PCR). All pesticides tested exhibited limited persistence, with spinosad demonstrating the highest persistence. None of the pesticides tested showed clear dose-dependent effects on NH4 + and NO3 - levels and the observed effects were <25% of the control, suggesting no unacceptable impacts on soil microorganisms. In contrast, q-PCR measurements revealed (i) distinct negative effects on the abundance of total bacteria and fungi, which were though limited to one of the studied soils, and (ii) a significant reduction in the abundance of both AOA and AOB across soils. This reduction was attributed to both natural products and 3,5-dichloraniline. Our findings strongly advocate for a revision of the current regulatory framework regarding the toxicity of pesticides to soil microbiota, which should integrate advanced and well-standardized tools. © 2024 The Authors. Pest Management Science published by John Wiley & Sons Ltd on behalf of Society of Chemical Industry.

Innovation incentives in technical standards

I study the incentives to develop complementary technologies and include them in a technical standard. I find that the standardization process may lead to insufficient or excessive innovation. Patent pools increase innovation incentives, while price caps may increase or decrease them. Although both policies increase user surplus and welfare, price caps dominate (are dominated by) patent pools if the incremental value of technologies is small (large). Preventing the coordination of price caps guarantees that the socially-optimal policy is implemented in equilibrium. However, from innovators' perspective, patent pools are more profitable than price caps. This finding helps explain why patent pools are more prevalent than price caps, even though price caps may imply higher welfare. Cooperative R&D agreements increase innovation and welfare when technologies are highly complementary. The paper's results contribute to the discussion of the effects of recent policy changes in the VITA and IEEE standard-setting organizations.

Investigating Patent Value and Litigation Probability of Global Technology Standards

Standard-essential patent (SEP) is a patent that claims an invention that must be used to comply with a technical standard. The issues of patent infringement are often at the forefront of the strategy and planning in patent litigation. Determining an appropriate methodology for valuing a patented invention is a complex and nuanced undertaking. This is particularly true for patent cases where the accused product or service includes many overlapping features and technologies. Patent information can be used in important issues of global technological standardization in order to evaluate the competitive potential of the SEP. This article makes two major contributions: First, it compares the patent value of SEPs with that of non-SEPs. According to the results, SEPs do have higher value, which indicates the effectiveness of the SEP system supported by standard setting organizations. Second, based on comprehensive observations of litigated SEPs, a model for predicting the probability of litigation is established and the litigation probability distribution of SEPs is plotted.

A U.S. Pharmacopeia (USP) overview of Pan American botanicals used in dietary supplements and herbal medicines.

The United States Pharmacopeial Convention (USP) is a nonprofit, scientific, standard-setting organization, and world leader in establishing quality, purity, and testing standards for medicines, foods, and dietary supplements. USP quality standards are used in more than 140 countries and are legally recognized by more than 40 countries. Currently, there is renewed interest in herbal medicines globally, and health policies are being implemented worldwide for the use of complementary and traditional medicine. In response, USP has developed a robust body of monographs that can be used to guide industry and regulators in ensuring the quality and safety of botanical ingredients used in dietary supplements and herbal medicines. Throughout the Pan American regions, there is a strong tradition of using botanicals as herbal medicines and, as in other regions, a growing desire for botanical dietary supplements. This underscores the need for public quality standards to ensure quality, reduce the flow of substandard and adulterated products, and ensure public health and safety. In April 2022, USP launched the Pan America Botanical Dietary Supplements and Herbal Medicines Expert Panel, with experts representing 12 different countries. The Expert Panel's work focuses on developing quality control standards for the most important botanical ingredients used in the respective countries, ingredients that are also of global importance. This article provides an overview of the state of botanical dietary supplements and herbal medicines in different Pan American regions with a focus on the regulatory status of herbal products, the development of national quality and research initiatives, and policies related to agriculture conservation and sustainability, among other topics.

Sustainability Reporting and Financial Performance of Oil and Gas Companies Listed in Nigeria

“Financial performance (FP) is a subjective measure of how well a firm can use assets from its primary mode of business and generate revenues. The term is also used as a general measure of a firm’s overall financial health over a given period.” A company’s financial performance refers to its health as a whole and the money it makes from its operations. Allocating resources effectively to meet objectives and boost profits is at the heart of this practice. The integrity of Nigeria’s oil and gas data relies on it completely. The sustainability of oil and gas in Nigeria is becoming questionable due to environmental factors that were not properly accounted for, and this prompted the researcher of this study to zero in on the effect of corporate social responsibility on the bottom lines of Nigeria’s publicly traded oil and gas firms. This study used an ex-post facto method for its research, using data from secondary sources such as annual reports and the Nigerian stock market. Inadequate CSR reporting and a failure to adequately reflect the financial performance of listed oil and gas firms have been noted in numerous works of literature. Using panel data analysis, the research correlated CSR reporting with the profitability indicators return on assets (ROA), return on equity (ROE), and return on capital employed (ROCE) of publicly traded oil and gas firms. This study looks at 10 Nigerian oil and gas firms that are traded on public markets. A filter was used with a census sampling strategy. Firms that (1) were permitted to trade before January 1, 2010, or (2) are still listed as of December 31, 2020 are eligible for review. In addition, the organization must publicly disclose yearly reports pertinent to the time under investigation. As a result of not meeting these criteria, four of the original eight firms were eliminated. Secondary sources were consulted to get the data needed. EViews 10, a statistical programme, was used to analyze the data for this research. The regression analysis showed that CSR reporting increases ROA by a small but favourable amount. The return on equity, however, was shown to be positively correlated with environmental sustainability. Finally, a statistically insignificant positive correlation was found between social sustainability and return on investment (ROI). Therefore, this study concludes, based on the data provided, that sustainability reporting significantly affects the company’s financial performance for listed oil and gas businesses in Nigeria. Based on the findings of this study, oil and gas companies in Nigeria should make public disclosure of their sustainability efforts a top priority if they want to improve their bottom lines. Compliance in the industry as a whole can be improved if policymakers and standard-setting organizations work together to make it easier for industries to design and execute sector-specific reporting regulations.

Determination of FRAND royalty rates: an examination of prominent SEP cases

Abstract Technology standards are critical in creating a common interface, allowing interoperability between individual components, devices and networks. Technology standards often incorporate many essential patented inventions, which are referred to as standard-essential patents (SEPs). Owners of declared SEPs provide commitments to standard setting organizations (SSOs) that they will license their SEPs on fair, reasonable and non-discriminatory (FRAND) terms to companies that practice the standards. However, it is sometimes disputed whether or not these royalty rates are FRAND; in these cases, the burden of determining a FRAND royalty falls to courts. It is important for parties involved in SEP litigation to be knowledgeable of the appropriate economic tools and models to address the various issues arising in these unique and challenging patent disputes. This article discusses how various approaches to patent valuation have been applied in prominent SEP cases over the last decade.

Co-Opetition and the Firm’s Information Environment

Some firms in the technology sector choose to cooperate with competitors (“co-opetition”) in standard setting organizations (SSOs). These SSOs create technology standards that facilitate rapid market penetration of new technologies such as Wi-Fi, Bluetooth, and 4G. Active participation in the standard setting process requires the exchange of proprietary information with competitors. Although the goal of such information sharing is to further a technology or a product market, firms potentially receive an additional benefit from access to competitor and industry information. We examine whether contributing to SSO committees enhances a firm’s information set and allows managers to better predict future sales. We find that the centrality of a firm’s location within the network of SSO collaborators is positively related to the accuracy of the firm’s sales forecasts. This relation is stronger when firms exchange more information with direct competitors and with larger firms, when forecasting is more difficult ex ante, and when firms forecast over longer horizons. Our findings show that collaborating with competitors in the product market provides an important additional benefit of improving the manager’s information set. This paper was accepted by David Simchi-Levi, accounting. Funding: This work was supported by the Wharton School, Institut Européen d’Administration des Affaires, the Institut Européen d’Administration des Affaires-Wharton Alliance, and the Mack Institute for Innovation Management. Supplemental Material: The data and online appendix are available at https://doi.org/10.1287/mnsc.2021.03152 .

Derivative Risk Information Disclosure Effect on Financial Reporting Quality Evidence from Selected Listed Deposit Money Banks in Nigeria

This study investigates the impact of financial derivative risk information disclosure on the quality of financial reporting in a sample of Nigerian deposit money banks. Data from the annual financial reports of twelve Nigerian listed commercial banks were collected over a ten-year period, from 2012 to 2021. While derivative assets served as the proxy for the independent variable, Jones Discretionary Accrual was employed to measure reporting quality and cash flow to asset ratio was employed as control variable. The hypothesis was tested using Pooled Ordinary Least Square regression analysis technique whose result indicate that disclosure of financial derivative risk information leads to an increase in discretionary accrual value, thereby undermining the quality of financial reports. As a result of this finding, the study concludes that disclosing financial derivative risk information has a negative impact on the quality of financial reports issued by Nigerian deposit money banks. It therefore recommends that policymakers work with regulatory bodies and standard-setting organizations to establish standardized disclosure practices for derivative instruments among Nigerian deposit money banks.

Market reaction to mandatory sustainability disclosures: evidence from Singapore

PurposeThis study aims to investigate the equity market reaction to sustainability disclosure measures derived from firms' inaugural sustainability reports following the implementation of mandatory sustainability reporting in Singapore.Design/methodology/approachThis study explores the equity market reaction to first-time sustainability reports of mandatory adopters and compares the reactions between voluntary and mandatory adopters. To mitigate any imbalanced distribution effects, entropy balancing techniques are employed.FindingsThe author observes a significant equity market reaction when mandatory adopters adhere to a reporting framework and release sustainability reports as standalone documents. Additionally, the study indicates that government regulation amplifies the equity market reaction for companies that include a board statement within their sustainability reports and present them as standalone publications.Research limitations/implicationsThe lack of quantitative information disclosed in the first-time sustainability reports may restrict the generalizability of the findings.Practical implicationsThe findings provide valuable insights for organizations and managers to evaluate the market's response to sustainability disclosures and improve communication effectiveness with investors. Furthermore, the study has direct policy implications for global standard-setting organizations in sustainability reporting. The findings support the notion that investors value market-led and investor-focused sustainability disclosures.Originality/valueThe study contributes to the limited body of research that examines the capital market effects of mandatory sustainability disclosures. To the author’s knowledge, this is among a few studies to directly investigate the equity market reaction to mandatory sustainability disclosures at the firm level.

INTUITION IN AUDITOR'S PROFESSIONAL SKEPTICISM

This article discusses the use of intuition by auditors, exploring its relevance for fraud detection. Auditors are expected to exhibit professional skepticism, which includes a questioning mindset and critical evaluation of audit evidence, but there have been concerns about insufficient use in the practice. While intuition is considered a dangerous trait for auditors due to the risk of biased decisions, it is an essential driver of practice, particularly for risk decisions. Despite the initiatives of professional associations of accountants and auditors, governmental regulators, and international standardization organizations to enhance knowledge about auditors' professional skepticism, there is still a lack of practical guidance on the appropriate use and how to document it. Therefore, the research question is how intuition can be used in the audit process to enhance fraud detection. To address this question, the article provides a literature review of normative, practitioner, and academic production on the use of intuition by auditors as a cognitive approach. The article concludes that the academic literature is scarce, and the normative resistance to the concept by standard-setting organizations may be the cause. The tension between the necessity of sufficient and proper documentation and the exercise of professional skepticism creates a paradox for auditors. Practitioners' commissioned research on auditors' skepticism is essential to bridge the academic literature on intuition and the rule-making by professional and standard-setting organizations. The article proposes a research agenda for the categories: Incentives, Time, Mindset/Prompts, Environmental and Contextual Factors, Competence, and Traits, suggesting alternative research methods such as case studies of corruption and financial scandals. This contribution is essential for auditors, accounting professionals, regulators, and scholars interested in the audit process and enhancing auditors' professional skepticism.

Standardising policy in a nonstandard way: a public/private standardisation process in Norway

Abstract Standards developed by standard-setting organisations (SSOs) – sometimes labelled private rulemaking – are part of larger practices of governance in most societies yet are underinvestigated from a policy process perspective. Utilising and developing the multiple streams approach (MSA), this article investigates a policy process moving between government and the SSO Standards Norway (SN). The study finds standardisation by SSOs to be an ambiguous institutional arrangement. Strong institutional barriers in theory did not work as such in the case investigated. This article argues that the differentiation between responsibility for process (SN) and content (committee) makes the standardisation process vulnerable. The concept of “institutional deficit” is introduced to describe a potential mismatch between SSOs producing policy in a government-like institution, but where the SSOs are not capable of taking responsibility for policies in a government-like way. This article finds the adjusted MSA useful in this potentially least likely case.