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TWIN PEAKS: YEARS AWAY Jamaica has missed two implementation targets. Richard Byles says Cabinet approval will be only the beginning. JAMAICA’S planned overhaul of financial regulation is likely to take years more to complete, outgoing Bank of Jamaica (BOJ) Governor Richard Byles has said, putting the Twin Peaks reform beyond both its original 18-to-24-month timetable and the Government’s subsequent 2026 target. Byles, who is scheduled to demit office on August 18, said the BOJ and Financial Services Commission (FSC) were close to submitting the proposed architecture to Cabinet. “Having brought it to Cabinet, remember now, really still we are at the beginning of the process,” Byles told the Jamaica Observer in an exit interview. “The laws now have to be drafted… and the two Houses [of Parliament] have to debate it before it becomes law, so we do still have years of discussion and work to do on Twin Peaks, even when it goes to Cabinet and even if Cabinet says yes.” Twin Peaks was announced in January 2023, shortly after disclosures of an alleged fraud at investment firm Stocks and Securities Limited intensified scrutiny of Jamaica’s regulatory system. The Government said the new structure would be implemented within 18 to 24 months, pointing to a transition between approximately July 2024 and January 2025. That deadline passed. In June 2024, then Finance Minister Dr Nigel Clarke told Parliament that implementation was expected in 2026. He said a concept paper prepared by the BOJ-FSC Twin Peaks Steering Committee had been approved and the Cabinet submission was in its “final stages”, after which drafting instructions would be issued. More than two years later, Cabinet approval has not been publicly announced. BOJ said in June that the architecture would “soon” be ready for Cabinet; its latest Financial Policy Committee statement said only that progress continued. It remains unclear how the concept paper approved by the then finance minister differs from the architecture Byles said was still being readied for Cabinet in 2026. Byles hoped the submission could reach Cabinet before its August break. He said much of the time had been spent obtaining comments from the agencies involved. “Any institution, not just the Bank of Jamaica, who has had to get legislation passed has found that that process is very cumbersome. It is onerous,” he said. Although Byles described the difficulty broadly as part of the legislative process, Twin Peaks had not yet reached formal drafting or parliamentary debate. Most of the delay so far occurred while the architecture, inter-agency comments and Cabinet submission were being prepared. MORE THAN MOVING REGULATORS The significance of the delay extends beyond a missed deadline. Until the laws change, Jamaica must continue regulating institutions largely by sector even though many operate in groups spanning banking, insurance and securities. BOJ supervises deposit-taking institutions, while the FSC oversees securities dealers, insurers and pension funds. Twin Peaks would divide the work by purpose. BOJ would supervise the financial soundness of institutions across the system. The FSC, or a proposed successor known as the Financial Services Conduct Authority, would oversee how firms treat customers, sell products, disclose fees and risks and handle complaints. A bank would therefore answer to BOJ for its financial health and to the conduct regulator for its treatment of customers. The same division would apply across the sector. The challenge is not simply transferring employees. The legislation must determine where one regulator’s authority ends and the other’s begins, what information they must share and how they will handle problems involving both financial safety and customer treatment. Poorly drawn boundaries could replace the gaps in the current system with either new gaps or duplicated regulation. The public documents reviewed by BusinessWeek identify neither a final list of laws to be changed nor a consolidated schedule assigning responsibility for each stage and setting consultation, parliamentary and legal-cutover targets. Jamaica is not starting from nothing. BOJ’s 2025 annual report identifies seven work areas covering supervision, consumer protection, legislation, staffing, technology, funding and Twin Peaks Practice. The regulators have trained employees and tested the approach across banking, insurance and securities within their existing powers. Operational preparation can reduce disruption, but it cannot substitute for law: Only Parliament can transfer the responsibilities and make the new system enforceable. One concern among non-bank institutions is whether BOJ would apply rules designed for banks. Byles said supervision would instead reflect each institution’s size, complexity and risk. “It’s not that we will supervise the non-banks in the same way we do banks, because the non-banks are a different animal and we have a concept that says ‘proportionality’,” he said. Proportionality would not exempt small firms. It would match scrutiny to the risks an institution presents and the wider damage its failure could cause. THE INTERNATIONAL LESSON South Africa’s experience shows why Byles’s warning should be taken seriously—and why long transitions still require clear deadlines. Its regulatory review began in 2007 and widened after the global financial crisis. Twin Peaks was formally proposed in 2011, followed by a draft Bill in 2013. The Bill was tabled in 2015, enacted in 2017 and the regulators opened in April 2018. The core transition took seven years from the formal proposal, or 11 from the initial review. Even then, the legal overhaul was incomplete. Cabinet approved a unified conduct Bill for submission to Parliament only in 2026-15 years after Twin Peaks was proposed. That history does not make Jamaica’s delay unavoidable. Its lesson is that South Africa managed a long process through a published roadmap, successive drafts, consultations and phased implementation. The United Kingdom moved faster, announcing its overhaul in 2010 and launching its regulators in 2013. There is no standard timetable, but reform is more measurable when divided into stages with clear responsibility. For Byles, Twin Peaks remains his most important unfinished reform. He expects it to continue because it is Government policy rather than a BOJ initiative dependent on his leadership. The next measurable step is Cabinet approval, which would allow formal drafting instructions to be issued. Legislation, consultation, parliamentary debate and legal commencement would follow. More than three and a half years after Twin Peaks was announced, Jamaica has begun practising the system but has not legally entered it. Cabinet approval would advance the reform. Byles’s warning is that it would also expose how much of the journey remains.