4.  Be More Swan: Practical steps for a sustainable solution: Manage 

In this edition of our Regulatory Change mini-series we look at three effective steps in the management of Implementing Regulatory Change which form part of the 9 step framework to ‘Be More Swan‘.


Put in place the strategic management and governance arrangements to allow rapid joined-up decision making.


Understand your global regulation roadmap


Proactively manage regulatory ambiguity


Actively manage cross-department stakeholders

1. Understand your global regulation roadmap

Regulation is global, with global impacts. The approach to regulator y change thus needs to be managed globally yet still have the flexibility to change direction quickly.

This requires an empowered global, joined-up decision making structure, supported by a roadmap that provides the very latest view of a joined-up plan as a basis for decision making. Constantly changing scope and timelines mean the roadmap needs to be actively managed.

This single view will allow synergies to be identified and a strategic view of where re-usable strategic solutions are best and where tactical solutions are most appropriate, particularly for technology.

Global regulation roadmap checklist

A single, actively managed, roadmap of in-flight and future planned and potential regulatory projects.

Regulatory initiatives aligned with the organisation’s wider strategic objectives.

A single global implementation governance regime which drives senior management decision making and controls a single regulatory change budget.

A global organisation structure for delivery of regulatory projects.

A standard regulatory project method to allow consistency and comparability of projects, and provide a basis for continuous improvement.

An IT planning methodology that is flexible enough to manage the frequent changes in direction.

Key interdependencies between regulatory initiatives and other portfolios (e.g. IT) understood and proactively managed.

2. Proactively manage regulatory ambiguity

Regulatory projects are usually dealing with a moving target and it is important to ‘get ahead of the game’ to drive out areas of ambiguity early and then close them out.

Defining scope – including which asset classes, products, trades and clients – can otherwise come too late as the devil is frequently in the detail, there are typically a large number of decision makers and time is required to get hold of the data needed to drive decisions.

Managing Ambiguity Checklist

Effective representation on industry bodies to drive the agenda, understand the nuances, pick up early warning signs and help seek clarifications.

A working group with all scope decision makers established at the start to drive decision making at pace.

An early working definition of scope inclusions and exclusions that is challenged by Operations and refined as policy is clarified.

Subject matter experts, with a good working knowledge of the organisation’s data infrastructure, used to help define scope.

A business case behind each project assessing alternative approaches to drive realisation of any potential benefits. (Regulators are increasingly interested in this area).

An IT planning methodology that is flexible enough to manage the frequent changes in direction.

Regular communication of the latest approach, including what is fixed and what is uncertain.

3. Actively manage cross-department stakeholders

A sophisticated focused approach to stakeholder management is a critical activity. Regulatory change initiatives often have impacts right across the organisation, typically involving Legal, Compliance, the Business, Client On-Boarding, Credit, Operations, IT and Reference Data Management. These business units are typically used to running operations in silos rather than coordinating management of complex tasks at low levels of detail.

We find this topic is best addressed strategically and not left to individual projects to lead as a ‘tick -box’ project management activity.

Stakeholder Management Checklist

Clear understanding of all internal and external regulatory change stakeholders and their goals, (including ISDA, regulators and competent authorities, industry group discussions, trade repositories and industry platforms).

A clear stakeholder and communications strategy and plan for the overall regulatory change agenda and for each individual initiative.

Senior stakeholders from impacted areas included in implementation governance and accountable for overall delivery in their business area.

Formalised delivery roles assigned to key delivery stakeholders, including regulation subject matter experts.

A transparent and flexible management information regime that provides tailored and frequent implementation information to each group.

In the next edition we explore the first of three editions on the Gate One Regulatory Change framework in “Practical steps for a sustainable solution: Deliver”.

Gate One

About Gate One

Gate One is a Business Transformation consultancy that specialises in the design and delivery of complex business change - Digital Transformation being a key focus area. We have a simple cause: to make your organisation better. We work in small teams embedded seamlessly alongside your own people. We have the knowledge, experience and approach to get to the crux of problems quickly, shape intelligent solutions and deliver tangible, lasting results which can be felt quickly across your organisation. To find out more please contact us.

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