
As with all regulatory change there is plenty to do with each participant on a sightly different point on the transition to compliance.
One of the things we stressed was that if you are good at regulatory change, know where your data is and what state it’s in and apply change discipline, this round shouldn’t be more difficult than other reg change – the rolling qualitative uplift expectations notwithstanding. If you don’t tick those boxes then the journey may be less pleasant.
Given that – one thing out of the NZ experience that perhaps puzzled some of our audience was the rollback of MIS licence holder obligations. While staying clear of a political position on this, there is a choice participants have to make between facing into a long view on transitional risk or hoping that short run relief from political change will persist.