Firms tend to treat regulatory change as something that happens on a fixed timeline — a consultation paper, a response period, a final rule, an implementation date. This framing misses the earlier signals that, in my experience, are considerably more informative than the formal timeline suggests.
Supervisors communicate their direction of travel well before any formal consultation, through speeches, informal commentary, and the questions they ask during routine supervisory engagement. Firms that pay close attention to these early signals — not to predict the exact rule, but to understand the underlying concern driving it — tend to be substantially better positioned when the formal requirement eventually lands.
I've advised firms that began building the operating model response to a regulatory concern more than a year before any formal rule existed, based on reading these early signals correctly, and firms that waited for the consultation paper to begin planning at all. The gap in readiness between the two groups when the rule finally arrived was considerable, and not easily closed in the time remaining.
This requires treating supervisory relationship management as a genuine information source, not just a compliance obligation — listening for what a supervisor's questions reveal about their underlying concern, rather than simply answering the specific question asked.
The regulation that eventually arrives is rarely a surprise to firms paying genuine attention beforehand. It's usually a formalisation of a concern that's been visible, to anyone reading carefully, for a considerable time before the formal timeline began.