Booooooooooooom!!!!!
Just joking. Makes absolute sense to me. To my simplistic view, as the Regs have grown they have been interwoven and exemptions included etc etc to the stage where trying to fix the mish-mash is so complicated it would be better to phase in a new suite.
There are probably all sorts of legal and regulatory considerations but your point is well made that it is highly unlikely a raft of Boards, execs, people, and committees have all been duds.
If what you are doing isn't working, time to try something different.
(Stands back with fingers in ears with 88 awaiting loud explosion)!
