Many thanks to The Investment Association for hosting a very informative and timely FX Global Code briefing, with Keynote Speakers from both the Bank of England and the FCA. Our key takeaways were:
- Clear links between FXGC and FCA's Senior Manager and Certification Regime....."We expect firms, Senior Managers, certified individuals and other relevant persons to take responsibility for and be able to demonstrate their own adherence with standards of market conduct. Our supervision of the SMCR rules supports this"
- Some jurisdictions are planning to embed the Code directly into supervisory guidance.
- A lot more to do on FXGC adoption, especially on the Buyside (MIFID II implementation has been recognised as a factor here)
- Similar to the additional work around Principle 17 Last Look, the Global FX Committee has additional work streams to review 1. Cover and Deal trading models, 2 Disclosures ( particularly in regards to anonymous E-Trading Platforms) and 3. Negative Pre-Hedging