Interestingly, the Grid indicates that roughly only a quarter or so of the listed initiatives are not affected by the pandemic in terms of their implementation. LIBOR discontinuance is the most notable of those and yet, although the ultimate expected timeframe is unaffected, there has been a shift in the intermediate milestones. See out IBORS microsite for more information on IBOR discontinuance.
The regulatory initiatives are categorised as either being generally applicable to all firms or impacting certain types of firm.
The regulators have assigned a view on whether the initiatives are high or low impact but this will very much depend on each individual firm's activities and business. It does not seek to identify where in a firm the initiatives will impact – risk, systems, capital, compliance, etc.
Whilst a regulated firm would need to consider carefully which initiatives they are impacted by, this is a high quality overview which will be particularly helpful for smaller and medium sized firms who may find it harder to horizon scan every pending regulatory development and plan for implementation accordingly.
What it does not do is indicate those current initiatives that still have pending Brexit uncertainties and the impact those may have if no resolution is reached. Another useful piece of work perhaps?
The Grid was scheduled to be published in the summer and provide a 2-year look-forward. Publication has been accelerated but only provides a one-year look-forward at this time. The Grid has been launched on a pilot basis and the regulators encourage feedback and engagement to make it as useful as possible.
If you would like to discuss how any of these initiatives may impact your firm, please do not hesitate to contact us.
Duncan Black | Partner
Guy Usher | Partner
Simon Lafferty | Senior Associate
Steven Burrows | Senior Associate
Please review our Covid-19 hub for updates and get in touch if you require further information.
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