Standards & Publications

Our outputs are Standards, Statements of Good Practice, and Spotlight Reviews developed by our membership and designed to illustrate best practice in areas of uncertainty to all market participants. Transparency Drafts are published for comment before the document is finalised.


Publication NameTypeDate of Initial ReleaseDates of Comment PeriodDate of Final Release
1Reference Price Transactions standard for the Fixed Income marketsStandard30-Jun-1630-Jun-16 to 8-Sep-1621-Nov-16
2Binary Options standard for the Commodities marketsStandard22-Jul-1622-Jul-16 to 14-Oct-1621-Nov-16
3New Issue Process standard for the Fixed Income marketsStandard18-Nov-1618-Nov-16 to 17-Jan-1702-May-17
4Surveillance Core Principles for FICC Market Participants: Statement of Good Practice for Surveillance in Foreign Exchange MarketsStatement of Good Practicen/an/a08-Dec-16
5Statement of Good Practice for FICC Market Participants: Conduct TrainingStatement of Good Practicen/an/a08-Dec-16
6Monitoring of written electronic communications Statement of Good Practice for FICC Market ParticipantsStatement of Good Practicen/an/a15-Sep-17
7Front Office Supervision Statement of Good Practice for FICC Market ParticipantsStatement of Good Practicen/an/a15-Sep-17
8Risk Management Transactions for New Issuance StandardStandard25-Oct-1725-Oct-17 to 20-Dec-1703-Jul-18
9Secondary Market Trading Error Compensation StandardStandard20-Mar-1820-Mar-18 to 20-Jun-1828-Jan-19
10 Suspicious Transaction and Order Reporting Statement of Good Practice for FICC Market ParticipantsStatement of Good Practice04-May-1804-May-18 to 03-Aug-1815-Jan-19
11 Information & Confidentiality for the Fixed Income and Commodities markets Statement of Good PracticeStatement of Good Practice01-Jun-1801-Jun-18 to 31-Aug-1803-Oct-19
12 Behavioural Cluster Analysis – Misconduct Patterns in Financial MarketsSpotlight Reviewn/an/a27-Jul-18
13 Misconduct Patterns in Financial Markets – Selected Case StudiesSpotlight Review (Case Studies)n/an/a27-Jul-18
14 Database – Market Abuse and ManipulationSpotlight Review (Database)n/an/a27-Jul-18
15 Conduct Risk in Market Transactions Statement of Good PracticeStatement of Good Practice27-Jul-1827-Jul-18 to 26-Oct-1828-Mar-19
16 Conflicts of Interest Statement of Good PracticeStatement of Good Practice20-Jun-1920-Jun-19 to 06-Sep-1914-Oct-19
17 Statement of Good Practice for Participation in Sovereign and Supranational Auctions in Fixed Income MarketsStatement of Good Practice02-Dec-1902-Dec-19 to 27-Jan-2014-Jul-20
18 Emerging themes and challenges in algorithmic trading and machine learningSpotlight Reviewn/an/a23-Apr-20
19 The critical role of data management in the financial systemSpotlight Reviewn/an/a11-May-20
20 LIBOR transition: Case studies for navigating conduct risksSpotlight Reviewn/an/a11-Jun-20
21 Algorithmic trading in FICC markets Statement of Good Practice for FICC market participantsStatement of Good Practice (Transparency Draft)24-Jun-202024-Jun-2020 to 21-Aug-2020Retired in Mar- 21
22 Examining remote working risks in FICC marketsSpotlight Reviewn/an/a27-Jul-20
23 Examining remote working risks in FICC markets – Risk registerSpotlight Review (Risk register)n/an/a27-Jul-20
24 Monitoring FICC markets and the impact of machine learningSpotlight Reviewn/an/a03-Aug-20
25 Measuring execution quality in FICC marketsSpotlight Reviewn/an/a07-Sept-20
26 Standard for the execution of Large Trades in FICC marketsStandard15-Dec-2015-Dec-20 to 16-Mar-2106-May-21
27 Standard for the sharing of investor allocation information in the fixed income primary marketsStandard (Transparency Draft)15-Dec-2015-Dec-20 to 16-Mar-21TBC
28 Standard on the use of Term SONIA reference ratesStandard24-Mar-2124-Mar-21 to 28-May-2128-Jul-21
29 LIBOR transition: Case studies for navigating conduct risks in back book transitionSpotlight Reviewn/an/a20-Apr-21
30 Spotlight Review ‘Hybrid working in FICC markets – Future risk management frameworks’  Spotlight Review n/an/a30-Sept-21
31Standard for the Conduct of Participants in LBMA Precious Metal Auctions  Standard (Transparency Draft) 12-Oct-2112-Oct-21 to 3-Dec-21TBC
32Spotlight Review ‘Precious Metals Market Structure’Spotlight Reviewn/an/a18-Nov-21

Transparency Drafts

All Standards and some Statements of Good Practice are published for feedback as Transparency Drafts. FMSB seeks comment on Transparency Drafts. Please click on the link below or email comments to secretariat@fmsb.com.

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Standard for the sharing of investor allocation information in the fixed income primary markets Transparency Draft

This Standard sets out certain expected behaviours of syndicate banks relating to the sharing of investor allocation information for new issuances in fixed income primary markets on the day of pricing within their institutions. The Core Principles seek to promote consistent baseline industry practices and provide both issuers and investors with certain protections and controls as to how their allocation information is used.

FMSB members and other interested parties are invited to comment on the proposed Standard. This consultation will run until 16 March 2021 with the final document expected to be published shortly thereafter.


Standards

FMSB Standards are intended to reduce the continuing uncertainty about acceptable practice in opaque and unregulated areas, which is a hazard for FMSB members (and other market participants). FMSB members are expected to adopt FMSB Standards in their businesses (where relevant) and to evidence this through an annual Statement of Commitment – see Adherence for more information.

Standard on use of Term SONIA reference rates

The Standard has been developed with the aim of identifying where there may be robust rationales for the use of Term SONIA for transactions in the loan, bond and derivatives markets and to set out certain expected behaviours of markets participants when using or issuing Term SONIA products in light of the reduced systemic risks […]

Standard for the execution of Large Trades in FICC markets

This Standard sets out expected behaviours for participants in FICC markets in relation to the execution of Large Trades. The Standard focuses on Large Trades due to the heightened conduct risks associated with their execution and the greater potential market impact of such activity compared with smaller transactions.  The Standard adopts a […]

Secondary Market Trading Error Compensation Standard

This Standard sets out expected behaviours that are designed to improve the practice regarding the payment of compensation for trading errors.

Risk Management Transactions for New Issuance Standard

The Risk Management Transactions for New Issuance Standard sets out expected behaviours that are designed to improve the practice and awareness regarding risk management activity that is conducted in and around the new issuance of bonds.

These improvements should enhance the fairness and effectiveness of the process for all market participants.

New Issue Process Standard for the Fixed Income markets

This Standard sets out enhancements to existing practices that are designed to improve the new issue process continuum (from the granting of a mandate to the publication of statistics), which improvements should enhance the fairness and effectiveness of the process for all participants, including issuers, investors and lead managers.

Binary Options for the Commodities Markets_Updated

The Binary Options standard for the Commodities markets Standard aims to describe the characteristics of a type of transaction which is used by participants in the Commodities markets and to set out certain expected behaviours of wholesale market participants that enter into them.

Reference Price Transactions for the Fixed Income Markets – Updated

This Standard aims to describe the characteristics of a Reference Price Transaction (“RPT”) and to set out certain expected behaviours of wholesale market participants that enter into them.


Statements of Good Practice

Statements of Good Practice reflect FMSB’s view of what constitutes good or best practice in the areas covered by the Statement of Good Practice in question. FMSB members are expected, and other firms are invited, to consider their own practices in light of relevant Statements of Good Practice and make any changes to such practices that they deem to be appropriate.

Statement of Good Practice for Participation in Sovereign and Supranational Auctions in Fixed Income Markets

A common way for government or supranational bonds to be issued is through a publicly announced auction. Auctions involve multiple parties/participants including Issuers (debt management offices/agencies/treasuries), Primary Dealers, Dealers and Investors. This Statement of Good Practice (SoGP) describes the way in which sovereign and supranational auctions are typically conducted in […]

Conflicts of Interest Statement of Good Practice

This Statement of Good Practice aims to provide practical, working level guidance and examples for market participants to draw on, as they consider ways to prevent, manage and mitigate conflicts of interest that arise within their firms.

Conflicts of interest may arise between (i) clients; (ii) a firm and its client(s); and (iii) employees and a firm/client(s). These conflicts have the potential to be detrimental, not only to the firms involved, but to clients and the financial markets more generally. Dealing with them effectively is one way in which instances of this kind of market misconduct can be minimised.

Conduct Risk in Market Transactions Statement of Good Practice for FICC Market participants

The Conduct Risk in Market Transactions Statement of Good Practice for FICC Market participants sets out Good Practice Statements for the identification of conduct risks in market transactions using this methodology. The identification of conduct risk is an important role undertaken by the Front Office, as well as by control and oversight functions, and firms should consider their own practices in light of this Statement of Good Practice and make any changes to such practices as they deem appropriate.

Suspicious Transaction and Order Reporting Statement of Good Practice for FICC Market Participants

Suspicious Transaction and Order Reporting Statement of Good Practice for FICC Market Participants covers the identification of suspicious orders and transactions and their reporting to relevant regulators (the FCA in the case of the UK). Many of the practices described relating to the identification and investigation of suspicious activity will be relevant to many jurisdictions.

Monitoring of written electronic communications Statement of Good Practice for FICC Market Participants

The Monitoring of written electronic communications Statement of Good Practice for FICC Market Participants is designed to be relevant to all front-office and control or support function personnel who are active participants in the FICC markets and to those who are engaged in the monitoring and surveillance of those activities.

Front Office Supervision Statement of Good Practice for FICC Market Participants

The Front Office Supervision Statement of Good Practice outlines good practice for the Supervision of front office activities that may directly affect the functioning of FICC markets and/or conduct with market participants.

Conduct Training

This Statement of Good Practice sets out a number of Core Principles relevant to conduct training, together with good practices that are currently used in Member Firms to achieve the outcomes specified in these Core Principles.

Surveillance in Foreign Exchange Markets

Set out in this document are a set of core principles for surveillance that firms may wish to adopt in order to identify, determine and establish an effective surveillance function.


Spotlight Reviews

Spotlight Reviews encompass a broad range of publications used by FMSB to illuminate important emerging issues in FICC markets. Drawing on the insight of members and industry experts, they provide a way for FMSB to surface challenges market participants face and may inform topics for future work. Spotlight Reviews will often include references to existing law, regulation and business practices. However, they do not set or define any new precedents or standards of business practice applicable to market participants.

Spotlight Review ‘Precious Metals Market Structure’

This Spotlight Review examines the existing structure of the precious metals market and makes a number of overarching observations as to how the market structure could evolve in order to promote fairness and effectiveness. In relation to each of these observations, the Spotlight Review considers the benefits that such changes could bring as well as the hurdles to implementation.

FMSB also issued a press release.

18 November 2021

‘Hybrid working in FICC markets – Future risk management frameworks’ 

This Spotlight Review examines a number of key benefits and potential conduct risks associated with the adoption of hybrid working models in FICC markets and considers how firms may look to adapt their risk management frameworks in light of such risks. It categorises conduct-related risks associated with hybrid working models into five thematic categories: cultural change, supervision and control impairments, execution risks, sharing of confidential information and threats to market effectiveness.  

FMSB also issued a press release. 

30 September 2021 

LIBOR transition: Case studies for navigating conduct risks in back book transition

This Spotlight Review examines certain risks to market fairness and effectiveness that might arise when transitioning existing LIBOR-based contracts with maturities extending beyond end-2021 to alternative risk-free rates. In particular, the Spotlight Review considers certain complexities associated with proactive transition of back book contracts through a series of practical case studies and sets out a number of key considerations for banks and end users when looking at different transition options and good practice observations for managing the associated risks.

FMSB also issued a press release.

20 April 2021

Measuring execution quality in FICC markets

Measuring and evidencing trade execution quality has become critical to client servicing as well as to demonstrating ongoing compliance with investor protection regulations. A firm’s ability to do this well depends heavily on the quality of data available.

While the various regulatory requirements for measuring execution quality vary by jurisdiction and asset class, wholesale fixed income, currencies and commodities (FICC) markets face specific challenges in achieving high standards of transparency, openness and fairness.

This Review examines the following topics:

  • the observability of relevant data sources;
  • the reliability and quality of data sources;
  • variations in data observability and reliability across different products;
  • obligations and priorities in measuring execution quality; and
  • a role for industry standards.

This Spotlight Review is intended to benefit front office trade execution on the buy-side as well as within market makers, and those responsible for overseeing regulatory requirements in compliance and risk functions.

FMSB also issued a press release.

7 September 2020

Monitoring FICC markets and the impact of machine learning

Market surveillance in FICC has undergone, and continues to undergo, significant change as a result of regulation, the evolution of market structure, and technological developments. This Spotlight Review considers these structural and technological changes, in particular the emergence of machine learning trading strategies, and sets out some of the challenges associated with these developments for surveillance teams in FICC markets. The review then examines the role of technology as a potential solution to these challenges, creating as it does opportunities to improve market surveillance through the application of machine learning.

This review outlines:

  • factors driving the pace of change in market surveillance;
  • the acute impact of data on surveillance effectiveness;
  • surveillance of complex algorithms and machine learning;
  • employing machine learning to empower surveillance; and
  • the vital role agility plays in effective surveillance.

FMSB also issued a press release.

3 August 2020

Examining remote working risks in FICC markets

Following COVID-19 being declared a global pandemic and the closure of many offices, FMSB formed a working group of members and other interested market participants to consider the impacts of financial services activities being undertaken by a workforce which is widely distributed and using remote working.

The working group set about identifying and capturing the main priorities from a wide range of risks that arise from the new working environment, with a focus on areas which impact the fairness and effectiveness of wholesale FICC markets, and then to consider mitigants or strategies to manage these risks.

This Spotlight Review includes a risk register that outlines over 40 risks drawn from the experience and observations of the working group for market practitioners to use when conducting their own risk assessments.

The risk register is available at fmsb.com/wp-content/uploads/2020/07/risk-register-examining-remote-working-risks-in-ficc-markets.xlsx

FMSB also issued a press release.

27 July 2020

LIBOR transition: Case studies for navigating conduct risk

The FMSB Spotlight Review ‘LIBOR transition: Case studies for navigating conduct risks’ includes good practice observations and practical case studies to support firms when considering the risks to fairness and effectiveness as the market moves to risk-free rates as more sustainable and representative benchmarks.

FMSB also issued a press release.

11 June 2020

The critical role of data management in the financial system

The FMSB Spotlight Review ‘The critical role of data management in the financial system’ examines the crucial role of data management in the stability and resilience of wholesale FICC markets and financial systems.

FMSB also issued a press release.

11 May 2020

Emerging themes and challenges in algorithmic trading and machine learning

The FMSB Spotlight Review ‘Emerging themes and challenges in algorithmic trading and machine learning’  highlights important emerging issues in this area to assist market participants in considering how to address challenges that may arise.

FMSB also issued a press release.

23 April 2020

FMSB Behavioural Cluster Analysis – Misconduct Patterns in Financial Markets

FMSB BCA research includes the analysis document and selected case studies as well as the BCA database of misconduct cases.

27 July 2018

Misconduct Patterns in Financial Markets – Selected Case Studies

FMSB BCA research includes the analysis document and selected case studies as well as the BCA database of misconduct cases.

27 July 2018

Market Abuse and Manipulation – Database of Cases

FMSB BCA research includes the analysis document and selected case studies as well as the BCA database of misconduct cases.

27 July 2018


Work In Progress

Standards, Statements of Good Practice and Spotlight Reviews are produced by FMSB’s cross-sectoral committees, sub-committees and working groups, each of which follows a rigorous production, review and transparency process. See our Organisational structure for more information.

Information about each of FMSB’s active groups is set out below with an update as at 6 October 2021. For an overview of all activity please see our ‘Progress on a Page’.

Behavioural Conduct Analysis (BCA) Committee

Chair: David Flowerday, EMEA Head of FICC Compliance at Citigroup Global Markets Limited

The BCA Committee was reconvened in April 2020 to produce a second edition of FMSB’s seminal Behavioural Cluster Analysis, published in July 2018. The primary aims of the second edition are to bridge the gap between the analysis for the 2018 publication and to include new misconduct cases, and to incorporate feedback on the use and engagement with the BCA from practitioners and other users. The group is progressing its analysis of cases, and drafting text with the ambition to publish an updated document in 2021.

Conduct and E-Commerce Working Group

Chair – Chris Dickens, COO EMEA Markets, HSBC

See below – Algorithmic Governance Working Group under the ETTC.

Conduct and Ethics Sub-Committee

Chair: Tracey McDermott, Group Head of Corporate Affairs, Brand & Marketing, Conduct, Financial Crime and Compliance at Standard Chartered

The Sub-Committee, together with the Remote Working Risks and Controls Working Group is focusing on the role of controls, competency and culture in driving  good  conduct outcomes in FICC markets. Work has recently completed on a publication on how existing risk management frameworks should be adapted in order to efficiently monitor and manage new and evolving risks deriving from hybrid working in a post pandemic environment.

The Sub-Committee is also considering the potential role, if any, FMSB can play in developing conduct training and qualifications. This will be reviewed further in 2021.

Electronic Trading and Technology Committee (“ETTC”)

Co-Chairs:

Zar Amrolia, Co-CEO, XTX Markets

Ciara Quinlan, Head of Electronic Principal Trading FX, Rates & Credit, UBS and FMSB Standards Board Member

The ETTC has been addressing two topics in separate Working Groups covering Trading Platforms and Algorithmic Trading – Governance and Conduct.

Trading Platforms Working Group – The Working Group is preparing a Statement of Good Practice aimed at promoting greater transparency as to how both bilateral and multilateral electronic trading platforms operate and seeking to harmonise the disclosures made by all trading platforms to their participants or prospective participants across FICC markets and asset classes. Increased transparency and standardisation of disclosures should in turn help minimise disputes between trading platform operators and their participants.

Algorithmic Governance Working Group – Following a review of the substantial body of international regulatory developments since The Algorithmic trading in FICC markets: Statement of Good Practice for FICC market participants was started, the decision has been made to retire this publication due to the conclusion that the original  purpose of the paper is now satisfied instead by regulatory guidance. The Transparency Draft published in June 2020 will not therefore progress to final publication.

The ETTC will now look to focus on other topics in the electronic trading arena, where regulatory guidance does not yet exist.

Emerging Vulnerabilities Sub-Committee

Chair: Joe Cassidy, Partner, KPMG

The Emerging Vulnerabilities Sub-Committee (EVSC) was established in April 2021 to undertake two important activities: (1) to maintain and prioritise a register of risks that form the basis of recommendations for future FMSB work on Standards, Statements of Good Practice or Spotlight Reviews; and (2) to monitor changes in FICC market structure that may create risks to conduct, market fairness or effectiveness in the future, i.e. recognise and evaluate emerging vulnerabilities.

Following a review and updating of the 2019 risk register and the implementation of a prioritisation & filtering process, a recent recommendation from the EVSC has resulted in the establishment of a working group which will now explore the implications of ESG Ratings in FICC markets.

Energy Working Group

Chair: TBC

The Energy Working Group was set up to review the fairness and effectiveness of business practices in the wholesale energy markets. An independent review of existing market practices has been undertaken to refine the workplan for the Working Group. Consideration is being given to a workstream considering issues associated with block trades as well as carbon credits.

Metals Working Group

Chair – David Tait, CEO of World Gold Council and  Member of the FMSB Standards Board

This Working Group was set up to review the fairness and effectiveness of business practices in the wholesale metals trading markets. Its initial focus is on precious metals markets. The Working Group has identified nine market features, which have been arranged into three themes: i) transparency and price formation; ii) post-trade effectiveness; and iii) market practices. These will be used to identify the issues the Working Group will examine. The Working Group has commenced the development of a Spotlight Review focusing on where and how existing practices could give rise to issues challenging the fair and effective operation of the precious metals market and how to address these challenges, and has also commenced work on a Standard relating to the provision of liquidity at LBMA auctions.

Rates Sub – Committee

Chair – Charles Bristow, Global Head of Rates Trading, J.P. Morgan and Member of the FMSB Standards Board 

The Rates Sub-Committee is considering topics and prioritisation of its future work.

 

Remote Working Risks and Controls Group

Chair – Rosie Murphy Williams (independent)

The group was set up in response to the impact of the COVID-19 pandemic on the operation of financial services activities and the consequent widespread use of remote working. FMSB harnessed the diversity of its member firms and other interested parties to pool experiences and share observations of risk.

Since the publication in July 2020, of a Spotlight Review on ‘Examining remote working risks in FICC markets’ which seeks to identify and capture the risks that arise from the widespread and prolonged period of remote working, the Working Group together with the Conduct & Ethics Sub-Committee, work has recently been completed on a publication on how existing risk management frameworks should be adapted in order to efficiently monitor and manage new and evolving risks deriving from hybrid working in a post pandemic environment.

Spreads Sub-Committee

Chair – Jonathan Brown, Head of Lending and Portfolio Management, EMEA, Barclays

The Spreads Sub-Committee has developed a Standard dealing with the sharing of investor allocation information. This Standard for the sharing on investor allocation information in the fixed income primary markets, which was published as a Transparency Draft on 15 December 2020, seeks to provide a consistent industry baseline standard for the sharing of investor allocation information with secondary market desks on the day of a new primary issuance and to provide both issuers and investors with certain protections and controls as to how their allocation information is used. The period for comments on the Transparency Draft closed on 16 March 2021 and comments received are currently being reviewed.


How does a typical Standard or Statement of Good Practice progress to publication?

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Annual Report

The FMSB Annual Report is published annually and sets out progress made by FMSB to enhance standards of behaviour in the wholesale fixed income, currencies and commodities (FICC) markets.

FMSB Annual Report 2020

The FMSB Annual Report 2020, published on 2 June 2021, presents the significant progress made during 2020 and outlines our priorities for 2021.  

FMSB Annual Report 2019

The FMSB Annual Report 2019, published on 25 February 2020, sets out our progress and key activities in 2019, and an outline of our work for 2020.

FMSB Annual Report 2018

The FMSB Annual Report 2018, published on 18 March 2019, sets out further progress made to enhance standards of behaviour in the wholesale Fixed Income, Currencies and Commodities (“FICC”) markets in the period from 1 August 2017 to 31 December 2018.

FMSB Annual Report 2017

The FMSB Annual Report 2017, published on 20 September 2017, sets out progress made to enhance standards of behaviour in the wholesale Fixed Income, Currencies and Commodities (“FICC”) markets in the period from 1 August 2016 to 31 July 2017.