Payment Services - Is the FCA using Covid-19 as cover to mitigate pre-existing concerns?

On 22 May 2020, the FCA published a consultation paper on coronavirus and the safeguarding of clients' funds. While the FCA stated that it was important, due to the exceptional circumstances of the coronavirus pandemic, to implement guidance quickly and without full consultation, there is a question as to whether this guidance really was to address temporary coronavirus-related issues or whether the exceptional circumstances have provided a useful hook to hang points raised in its 2020/21 Business Plan. 

 The safeguarding rules were already in place, as prescribed in the PSRs, likewise, the governance requirements. The FCA confirms that the guidance is to deal with shortcomings it has evidenced in the sector, some of which pre-date the exceptional circumstances by some time. And is this really temporary guidance? With a full consultation set for later in 2020/21 which will likely include a proposal to incorporate this guidance, I suspect not.