Tucked away on page 100 of the document published alongside chancellor Rishi Sunak's first Budget on 11 March was an announcement that HM Treasury would establish a Financial Services Regulatory Initiatives Forum. This Forum, comprising the Bank of England and the Prudential Regulation Authority (PRA), the Financial Conduct Authority (FCA), the Payment Systems Regulator (PSR) and the Competition and Markets Authority (CMA), with the Treasury in observance, would provide industry with a forward-look of upcoming regulatory initiatives. This promised to deliver UK Finance's recommendations for a shared business plan and air-traffic control in response to the Treasury's July 2019 call for evidence on regulatory coordination.

In early May the Forum published the first iteration of its Regulatory Initiatives Grid (the Grid). This laid out information about the timing and estimated operational impact of major regulatory initiatives and highlighted those cancelled or delayed as a result of Covid-19. In a joint foreword to the Grid, Chris Woolard, interim CEO of the FCA and Sam Woods, CEO, PRA emphasised the importance of coordination between regulators in maximising firms? capacity to support their customers through the pandemic.

Today we published our feedback to Forum participants on this first Grid. We welcome its publication as firms will greatly benefit from the information provided about the timing of initiatives that may have a significant operational impact on them, particularly as they continue to focus their efforts on supporting customers through the ongoing disruption caused by Covid-19.

We nonetheless suggest a number of presentational and process-related improvements to the Grid that would make it even more useful as a planning tool for firms. These include making the Grid more easily digitally manipulated and grouping initiatives by important themes such as ?climate, environment and sustainability? and ?data, digital and innovation?.

While we agree with the Grid's emphasis on the likely operational impact of an initiative on firms, our feedback notes that it doesn't set out the methodology for assessing an initiative's impact beyond its being ?likely to take up a meaningful amount of firms? time and resources?. More information about the factors considered in making these assessments will inform firms? own internal assessments of impact and facilitate debate about significant discrepancies. There are no predetermined criteria, but firms usually consider a multitude of metrics to help define the operational impact of an initiative, and we would encourage Forum members to do the same and publish them in the interests of transparency.

At present it's difficult to fully determine whether the sequencing of initiatives set out in the Grid is satisfactory owing to the significant number of key milestones listed as 'to be announced.? We appreciate these reflect the ongoing uncertainty resulting from Covid-19, for firms and Forum members alike, but would welcome clarification as soon as possible about when appropriate postponed initiatives will resume.

Our feedback also expresses our members? concerns about the possible clustering of operationally significant milestones in important initiatives, including the onshoring of the EU acquis, within a relatively narrow timeframe around the turn of the year. Without active and conscious efforts at sequencing, there's a risk that their cumulative burden will adversely affect firms? ability to focus on supporting customers, businesses and the wider economy as they recover from Covid-19. As such we urge the Forum to give careful consideration to the sequencing of these timelines as it produces the next version of the Grid later this year.

Most significantly, we ask the Forum's members to recognise that the markets they regulate will change - in some cases fundamentally - as a consequence of the pandemic and the measures taken to protect consumer and business livelihoods. In the current climate, the continued relevance of the regulators? pre-crisis business plans, priorities and intended actions should not be assumed.  We therefore strongly recommend that the Forum's members consider not just when they reintroduce initiatives that have been postponed but also whether or not they should do so. Regulators should rightly continue to protect consumers and market integrity and promote competition, but good coordination of outdated policies will not serve those interests.