The rules will require some tweaking here and there — and the FEMR would be a good opportunity to do a bit of spring cleaning — but the overall framework is something that is well established and that everyone can understand.
The problem the City faces is that once the new rules are finalised there will be a great deal of pressure on the FCA and its staff to make use of them.
The City’s former enforcer-in-chief, Margaret Cole, established the principle of “credible deterrence”, when she started aggressively — and successfully — pursuing insider-trading cases.
When the regime has been extended, Ms Cole’s successors, bluntly, will need to demonstrate that they can secure some scalps of their own, if only to establish its credibility.
Business news in pictures - May 26
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The City is already feeling the heat through the imposition of the senior managers’ regime, which requires bosses to demonstrate they made every effort to ensure rules were obeyed in the event of things going wrong.
But the thermostat is about to be turned up again, and given the cesspits exposed by the most recent set of misconduct investigations, there will be scant sympathy for anyone who tries to complain about it getting too hot.
