This publication provides a high level summary of the developments to which reference is made and is based on information derived from external resources. That information may be subject to change and DLA Piper UK LLP accepts no responsibility for its accuracy. This publication should not be used as a substitute for taking legal advice in any specific situation and DLA Piper UK LLP accepts no responsibility for any actions taken or not taken in reliance on it.

The Financial Services Regulatory Initiatives Forum (the Forum) launched earlier this year. It is formed of the Bank of England, Prudential Regulation Authority, Financial Conduct Authority (FCA), Payment Systems Regulator and Competition and Markets Authority (with HM Treasury as an observer). It is intended to improve and assist regulatory co-ordination as well as giving firms a clearer picture of the horizon for significant regulatory initiatives.

Scope

On 7 May 2020, the Forum launched a new Regulatory Initiatives Grid, listing the regulatory initiatives whose implementation is expected to have a significant operational impact on firms. The grid is formed of two parts: a high-level one-page map of the “key initiatives in the regulatory landscape”; and a more detailed grid, split out by sector (including a section for multi-sector initiatives).

The sector specific grids are based on the FCA’s standard categorisations:

• banking;
• consumer credit;
• payment services and market infrastructure;
• insurance and re-insurance;
• pensions and retirement income;
• retail investments;
• investment management; and
• wholesale financial markets.

It includes a number of indicators to assist firms with operational planning and risk assessment activities.

• Indicative impact – An indication of whether the operational impact (on firms within the scope of the initiative) of implementing the initiative is assessed as high or low. This is assessed by comparison to other initiatives listed in the grid. Of course, the actual impact will vary between firms and it remains important to conduct timely impact assessments and cost-benefit analysis.
• Timeline – indicates the level of likely engagement required of firms across the next 4 quarters (and post March 2021).
• COVID-19 – identifies initiatives for which the timing has been amended to accommodate the impact of the COVID-19.

Limitations

• Information gaps - The launch of this tool has been fast-tracked in a bid to help firms stretched by responding to the impact of COVID-19. Consequently, there are more initiatives with indicative or indeterminate timings that the Forum would expect in a business as usual context.
• Fixed in time - The grid is accurate as at the date of publication and will not be updated in between editions (expected to be twice a year). Nonetheless, the timing of initiatives will continue to flex, now more so than ever.

Next steps

The high-level map identifies that the unfortunate combination of COVID-19 and the Brexit transition period is likely to result in the finalisation of a substantial volume of policy around the turn of the year. Firms can reasonably expect to feel the operational impact of this next year.

In consideration of the uncertainty created by COVID-19, there will be a further period of reprioritisation by Forum members. It would be reasonable to expect this to result in a further edition of the grid, but there has been no commitment to this.