The Development Stage: A journey begins with the first step – and the support of a critical friend

21 February 2019

In this second article on the new Development Stage in the Modifications Process, we explore how you can raise a new Draft Proposal, so your issue can be considered.

If you are looking to raise a change to the SEC, your first step is to contact us. We will help you in creating a problem statement and identifying the impact of the issue you have identified. We will be updating our website to help make it easier to submit a new issue, but in the meantime please email us at with your draft problem statement. There is no ‘proposal form’ at this point in time – your issue will be developed into a full proposal by the end of the Development Stage.

At this point, we are not seeking a solution; in fact, you don’t even need an inkling of what a solution might be at this point. The purpose of the Development Stage is to first ensure the scope of a Draft Proposal is sufficiently understood. This is achieved by agreeing the problem statement, which any subsequent solution will be measured against. Indeed, putting forward a preferred solution up-front runs the risk of muddying discussions as people’s opinions on the issue may be swayed by their views on the potential solution, resulting in a less effective outcome.

The Development Stage also allows for issues to be discussed and developed with the wider industry, through consultations or workshops. This will help in understanding what the problem is, the causes and magnitude of this problem, whether it is an issue with the SEC arrangements, and the support for taking this further.

Don’t forget – we are here to help and will play the part of the critical friend. Once you send us over your issue, we will take a look with the help of our experts. We will then provide you with our thoughts and, where appropriate, challenge on your problem statement and how it could be developed. We will also advise you, based on our experience, on our initial views to the questions posed in the first part of this series as well as potential timescales for progressing this through the process. We aim to provide our comments within five working days, so we ask you allow for this when planning your submission, and please don’t leave it until the last minute!

All this is meant to help you get your Draft Proposal in the best possible shape – the better shape it is up-front, the smoother your proposal is likely to progress. However, it is up to you whether to take our comments and advice on board – ultimately, it is your proposal.

Once we have provided you our thoughts as a critical friend and you have confirmed the draft problem statement you want to put forward, we will give it a number and raise it as a Draft Proposal. From here, it is presented to the Change Sub-Committee and opened up to wider scrutiny, which we will cover in the next article in this series.