As European, US and Asian bodies ramp up their regulatory initiatives, the pressure on stakeholders' ability to write successful comment letters is increasing.
With often small windows to submit comments but swathes of the financial sector relying on well argued points, those responsible for drafting the letters need to know how best to do so.
But there is little information available on what regulators value most in comment letters. And many in the industry are uncertain.
"I have never had anyone tell me that they didn't understand my response, so it's hard for me to change my style," said Ruari Ewing, director at the International Capital Market Association (ICMA).
Ewing writes comment letters extensively on primary markets and regulatory policy on behalf of ICMA's members. "It might be that they haven't read my response – though I doubt it. Or it could be fine, or good enough. I don't know,"...