The perfect storm ... or for some the perfect nightmare.

 

In Wikipedia the term "a perfect storm" is decribed as "an expression that describes an event where a rare combination of circumstances will aggravate a situation drastically." In the many years I have been working in change I am not sure I have seen a "perfect storm" shape up as well as the one we face now.

We have:

• a deadline whose definition is defined in European Law and will not be moved,
• a change that impacts pretty much the every bank and investment manager,
• has regulatory requirements that have not been fully defined yet and are not expected to be published until maybe two weeks or so before the due date (and could be later),
• rely in industry-wide agreement on the creation and communication of key data elements that have not be resolved with less than a month to go, and
• has critical supporting infrastructure that we are told may only be released on the eve of the due date.

When pushed the response from key parties is (almost literally) "suck it and see". By that they mean  give it a go, submit trial files to the receiving computer and see how the computer responds. This is not the measured and controlled way we look to deliver change in financial services, but is the only one open to us.

The situation is widely recognised by those involved and those responsible. The regulators have said they expect everyone to start on the due date on a "best endeavours" basis, but no-one knows what will qualify as acceptable "best endeavours". This is not the regulatory world many senior managers are used to, so you can understand their unease and unwillingness to be open about where they are.

The grapevine suggests that many big names will not be ready - indeed how could they - but like a giant game of chicken no one is blinking yet and the regulators are sending all the signals that they will not move.

What am I talking about? Well, if you haven't guessed yet it is EMIR Trade Reporting.

The next few months could be a bumpy ride with many firms (operations, compliance and change) needing to be truly agile as they take what they can and deliver what is possible, probably in iterative steps. The 12 February 2014 is far from the end of this work. Instead, I suspect it is just the beginning of something we have not seen before.

The Chinese have curse that goes, "May you live in interesting times." We are certainly living in interesting times so I wonder what we did wrong?