This morning I read with interest a colleague’s blog post on the delay to the publication of the ESMA technical standards from July back to September. Whilst I appreciate that these things are complicated, it seems hard to understand how this won’t delay the implementation date without potentially increasing the very risks the regulations are trying to prevent. Building software and systems properly isn’t just a question of resource; it’s just as much about process. Here at Fidessa Towers, for example, we work on a quarterly release cycle. Next quarter’s code is being loaded onto the waggons to be shipped, the release 6 months away is being tested, the following release is being programmed and the release a year out is being designed. Only by taking a disciplined approach like this can we manage to produce high quality software that meets its functional objectives and get it properly deployed for customers. For major banks trying to implement this software, the problem is even worse as they face far greater conflicting priorities against the same moving global regulatory feast.
I fear, therefore, that the venerable Dr Voigt is right and that our industry is being served an unpalatable appetizer of unintended consequences before we have even taken our seats at the table.