If you have any doubts about the extent and complexity of the waterfront the FCA is charged with scanning, its Business Plan, published on 19 April, should put them to rest.
Here is our summary of its contents, and a tally of the various risks, issues and outcomes listed in its 100 odd pages quickly reaches daunting levels, even before taking account of the various market studies and EU Directives.
By its nature also, the Business Plan is relatively silent on the various systems and high volume processes involved in Authorisation and Supervision, as well as the high impact Enforcement cases in the pipeline for this year. So it's a reasonable assumption that the FCA and many firms are likely to remain at full stretch.
For firms seeking to interpret what the Business Plan means for them, the FCA Mission statement (we'll be posting a summary soon), published at the same time, is a good start, but so far lacks a lot of the crucial detail. Hopefully much if this will be supplied by the various approach documents promised for later in the year.
The other key perspective is the sector view. We plan to publish our initial analysis of these next week, and in this respect the Business Plan is relatively helpful. Although again, as David Morrey observes in his overview, the FCA has left itself some room for manoeuvre. Ultimately, this is probably wise, given the unknowns of Brexit and the reality that events -"crystallised risks" - have a habit of disturbing the best thought-out timetables.
The skill for firms will be to understand where the various regulatory activities that apply to them intersect and what are the strategic and operational dependencies involved, and then to manage its relationship with the FCA on that basis. Ringfencing and cyber is flagged as one but there are several more.
Treating each initiative wholly in isolation is, I suspect, much more likely to cause sleepless nights.
As in prior years the Plan contains details of upcoming Thematic Review work, however it is notable for the number of areas and issues where it is indicated some work will take place without defining what (or when) that work might involve. For instance, work on remuneration structures is signalled as is a ‘review’ of motor finance.