Wednesday's consultation on extending the SM&CR regime, beyond banks and insurers, to almost all regulated firms (c.47,000) is in many ways regulation at its best. In it, the FCA has made a valiant attempt to scale SM&CR for firms of different sizes and complexity, while preserving the central tenets of the existing regime.
Yet it is far from obvious the reforms will have the effect politicians and regulators hope. It's worth remembering that the target of the Parliamentary Commission on Banking Standards - part of the political response to the financial crisis - which made the original recommendation in 2013, was the senior management of large banks. So the logic of applying even a narrower version of the same regime all the way down the scale to Dentists is at best debateable.
But however you view them, the FCA's proposals will play a major part in framing UK regulation over the coming period. This is my initial attempt to understand some of the changes they will bring.
To satisfy the demands of proportionality, the FCA is introducing an enhanced regime, applying to less than 1% of firms, and a core regime for the remaining 99%. Crucially, however, in an attempt to meet the requirements of consistency, the central elements of the existing regime are applied to all. Only time will tell if this is an elegant solution or an unworkable mismatch.