Last week Eumaeus posted Dean’s response to the PRA’s Consultation Paper CP 2 20.
Here is mine.
My first impression about CP 2/20 is one of overwhelming bafflement. The PRA has a statutory duty to consult when proposing new rules, but there is also an implied obligation to consult clearly and intelligibly.
It is one thing for the Regulatory ‘Will’ to be inscrutable, but it is quite another when that Will becomes inscrutable to the point of unintelligible. CP 2/20 reads as if it could have been written by Hegel on an off day.”