Transcript of Question & Answer Session The Global Foreign Exchange Committee and the FX Global Code

So let me finish there and open it up for questions, which I'm going to confine to questions on the topic today rather than on conjectural issues. So, happy to take questions on the issues that the GFXC is looking at. I understand if people type their questions in the chat box, I will be able to then answer them.

So the question, is there any work being completed with WM/R specifically with buy-side users of the 4pm fix to educate the relevance of stack in trade and swap value at this time of day, and moving to different styles of benchmarking against alternative approaches?

It's a good question. The point that the GFXC has been at pains to emphasise for quite a long time, and including previous work I did under the auspices of the FSB, Financial Stability Board about seven or eight years ago, which resulted in the widening of the 4pm window from two to five minutes. One thing we've been at pains to emphasise over the past seven years or so, and including again recently, is people have got to think about why they're using benchmarks, and particularly the 4pm fix and consider whether that is best execution for them. And so we have been trying to educate people about the relevance of that fix and whether that is the most appropriate thing for them to be doing depending on what their objectives are. So that has been an ongoing discussion over a long period of time.

I suppose from WM/R's point of view, they are the provider of the fix. So they are engaging more with the market, and beefed up their user groups over the last year or so, which does contain both sell-side and buy-side participants. I would highlight that WM/R is now providing the minutes of those discussions, including their discussions about the appropriate width of the window at the fix as well. So, I would very much encourage you to have a look on the WMR website around FX fixes and you can find more information about the sort of issues that WM/R is considering. From our point of view in thinking about usage of the fix, we are very much continuing to emphasise that people really need to think about whether usage of the fix remains fit for their purposes, be it the 4pm Fix or any other fixes.

I'm not going to talk about conjunctural questions, but I'm certainly happy to take further questions on the issues that we're seeing around settlement and the like as well. So two minutes left, if there are any further questions before we head to a discussion particularly focused on buy-side adoption in a minute.

Another question, has there been discussion with the likes of MSCI and FTSE with respect to the use of WM/R benchmark rates?

We did have discussions certainly with MSCI back when we did the FSB review, but we haven't had any recent discussions with them lately in terms of the way that they incorporate the WM/R fix into their benchmarks. But again, I would encourage people who use those other benchmarks to understand how they're incorporating the 4pm fix or whatever FX fix they're using into those calculations. As I said, people who are going to be using the fix, I think it's important to understand how the fix is being generated, and think about whether that's exactly the purpose that you want it to be put to.

So let me maybe finish there, and I'm about to re-join you in a second for a chat about the general adoption of the Code. Thanks.

Hello, again, slightly different venue, but happy to be joined by Susan Buckley from QIC and David Mercer from LMAX Group. Susan, I think, will mostly chair this session. Let me just start off talking about the future of the Global Code and whether it should remain voluntary. So let me give you a bit of history about how we ended up where we are, and about why it is voluntary. So the first point to note is that the Global FX Code is indeed that, it's global. We have 20 Foreign Exchange Committees from around the world, right across all continents, both EM and advanced in G10 currencies, and so a wide breadth of different FX markets. And one of the main purposes, as I said a few minutes ago for putting the FX Global Code together was to have one common code of better practice for the whole FX market, rather than the multiple FX codes we had prior to that.

So that's the reason why we have one Global Code. Currently we have more than a thousand signatories, more from the sell-side, than from the buy-side. Those signatories are also from right around the world, and there's particularly strong take-up in Asia across the banking sector, as well as the buy-side. The Code is principles-based and it isn't regulation. Basically for the reason that from my point of view, if you try and approach this with black letter regulation, you're basically doomed to fail because of the complexities of the FX market. Looking at the experience in other markets, I don't see that black letter regulation has necessarily been all that successful there. So hence the Code is principles-based, and also it reflects the fact that we are across multiple jurisdictions each with their own regulatory arrangements.

So, trying to work within the regulatory arrangements of each country meant that a regulatory approach was probably doomed to fail as well and hence why we landed on the principles-based approach. That said, in some of the jurisdictions, including here in Australia, but also in the UK, the securities regulators use the Global Code in their surveillance of the FX market. So ASIC here very explicitly uses the FX Global Code in its surveillance of FX market participants, and similarly the FCA in the UK references the Global Code in terms of its oversight of the FX market. A not dissimilar situation in both Singapore and Hong Kong. In China actually it is law, the FX Global Code has been written into law in China, but they are the only country which has approached it from a direct regulatory point of view. Rather, as I said here, and in the UK, for example, it very much references the Global Code in the regulators approach to the market, which I think is actually a reasonably workable model. ASIC has referenced the Code in some enforceable undertakings it's taken against some of the banks in this market over recent times, and I think that has proven to be effective.

So I do think the Code can remain voluntary, but I do think it is also helpful where appropriate to have that regulatory backing to it. But I do also think that a complete regulatory approach to this is probably doomed to failure in large part because of the fact that the FX market is a global market. It isn't a local market like an equities market or a bond market. It is a global market often with participants on each side of the trade sitting in different jurisdictions. And hence, if you were to go down a regulatory route, you'd have to be very mindful of that, and the only way you could potentially do that would be a global regulatory solution, which I don't think is feasible.

So hence I do think it needs to remain voluntary, but I do think some of that backing like we have here in Australia and similarly in the UK, certainly can be beneficial. As I said, we've got over a thousand signatories now as I said in the talk just now. If I look at it from the buy-side point of view, where take up has remained less than on the sell-side, we have seen that of the top 30 asset managers, now more than half of them have signed up to the Code. So out of the top 30 asset managers by size around the world, more than half of them have signed up to the Code, which is a better state of affairs than where we were a couple of years ago.

And in each of the various Foreign Exchange Committees around the world, including here in Australia, we are reaching out to, and talking to these asset managers, the large ones in particular, and trying to talk to them about the potential benefits to them, of signing up to the Code, trying to understand what issues they might have as to why they're not, if that is the case, and trying to address them where possible, provide comfort to them where possible. So in that ilk, let me hand over to Susan, whose institution is an asset manager who has signed up to the Code, and I'd be interested in hearing her thoughts on that. Thanks Susan.

Thank you, Guy, hello everyone, and thanks Guy for that context and background. And certainly I think we're all similarly motivated here on this fireside chat and beyond to see the proper, robust, liquid and effective functioning of this largest global financial market being the FX market, and see this continue well into the future. So similarly, I agree with the self-regulatory approach and the voluntary take up of the Code. And Guy did mention the low buy-side take up, and I guess I might just kick off with the motivation for QIC being an early signatory to this Statement of Commitment to the Code, and it was important for us to have that public statement in demonstrating not only within QIC the best practice standards that we put on ourselves, but also role modelling and signing up publicly to support the industry in employing these best practices and ensuring that we've got a fair, effective, resilient, and liquid FX market.

And I think from a buy-side perspective, signing up to the Code does help foster this level playing field, alongside our sell-side industry participants and noting that the industry is still somewhat fragmented, and increasingly fragmented given electronic qualification and the Code helps us get to that one standard. So, more broadly, this Code for the FX market, and it's very applicable, more generally across financial markets, fits with QIC's focus on the G of the ESG principles that have been in discussion for many years now. And it gives me a lot of comfort as head of the business, the liquid markets business of QIC, that we have signed up in August 2017, to apply these best practices within QIC and support the industry in applying these best practices as well.

And then also being part of the dialogue in how the Code meets these standards, how it will evolve and be future proof for the years ahead. So whilst, I guess I'm not a specialist FX trader or specialist head of currency, we have Stuart Simmons in that role for QIC, from my perspective as the head of the business, it was very important to support the signing up of the Code and we really do need to discuss the reluctance or the reticence from some of the other buy-side participants? I think we've got less than 10% of signatories to the Global FIX Code from the buy-side. We can go into that a little bit more detail later, but we really should be turning the question around in terms of why CEOs and Boards and not asking why their organisations have not signed up to the Code and we can come back to that question. So I might just hand over to David now from that platform perspective, which is a different perspective again.

Thanks Susan. Thanks Guy. So, hopefully everyone watching knows who LMAX Group are. We operate foreign exchanges globally. We've been in operation for a decade. We've always had a public rule book. And then you're probably asking yourselves why are you here, David? Why are you in a Code conversation? But a little-known fact about LMAX Group is that we were the first signatory to the Global Code. That said, I don't agree with everything in the Code. And Guy knows that well, specifically we can talk about principle 11, principle 17, but my point being, it's okay to disagree. And I think one message overall I'd like to send back to the GFXC, and in fact the whole FX industry, is better to engage, or there's another saying about that. But better to engage and better to listen to a rounded different view of the FX marketplace. Frankly, we wouldn't be in existence as a group if there wasn't a need for transparency in the FX marketplace. Specifically, if I look at it from an LMAX perspective, we only do foreign exchange.

The so-called primary venues, I call legacy venues, and the ‘last look’ ECNs, are now owned by securities exchanges. We care about foreign exchange. At LMAX Group, we care about foreign exchange. And part of that is that we believe in that level playing field. And we also believe vehemently that the FX industry should be self-regulated. But for that to continue, we need to agree to a code of conduct.

And I'd like to congratulate everyone who has put it together and certainly led by Guy currently and everyone in all the working groups. They've done a great job. Probably 55 principles is too much. Yeah, probably some of those you don't agree with, but we've got to get behind it and we've got to engage. And I'd say to the working groups, don't be afraid to engage with someone here, for example, who doesn't agree with your view? The chair of a working group shouldn't necessarily be an advocate of one side or the other, but frankly, the alternative, and Guy's touched on it, the alternative is that we go for more stringent regulation and there's a lot more regulation that you're not going to agree with than what's in the Code today. That's just the way it is.

I'm a very heavily regulated Group. I'm regulated as an MTF in the UK, by the FCA, I'm regulated as a broker in the UK and I'm regulated in five other jurisdictions around the globe. It's difficult and there's a hell of a lot of that regulation I don't agree with, but so what, right? That's the rules, David, best abide by them. The difference with this Code is we have input as an industry. So best we get behind it, best we engage, and best we try and make it better. And then we can actually make the largest asset class in the world, the most trusted asset class in the world, the most efficient asset class in the world and continue to be a self-regulated asset class. I rest my case. I'm sure we've got a lot more to discuss.

Thanks, David. We might just come back to that question of why there is this low take up from the buy-side. And maybe if I just talk through that and Guy, you might have some comments as well. I think, and certainly, David mentioned the 55 principles, there probably is some reticence because of the degree of proportionality that may need to apply. So from a QIC perspective, we think that there are 40 of the 55 principles that are applicable to us and we hold ourselves to the standards of those 40.

So every institution and firm probably needs to then think about the direct or indirect activity that they have in the FX market and which principles are most important. But the framework is certainly comprehensive. The 78-page document is certainly a great framework to have a constructive dialogue both internally and then with the liquidity providers in the market.

And it's pretty much, as David said, an off-the-shelf ready to go framework for you to think through how that applies and it has obviously taken many hours of work to get it to this point. And I guess I would probably emphasise for those that think, well, it doesn't apply to us; we don't do FX; we don't trade FX, that's done by a fund manager. I think for every super fund out there, I think it's important for CIOs, CEOs to be thinking, well, how does this apply to our fund? If we're signing up to this standard and this Code, ensuring that that other managers and then counterparties are also a part of this industry practice. And then, I think beyond that, there's obviously a whole corporate industry segment where there is also applicability.

So, there is that proportionality element. I don't think it applies to me because my fund manager does that. Or then there's probably a general awareness too, as Guy said, in terms of all the other priorities on the list of super funds and corporates and so on, where this fits, and this will take some time and resources to think through and it does need a champion. I guess we've been fortunate at QIC to have those subject matter experts to really believe and champion the cause in the applicability of the Code. And these champions feed up through to the executive, and through to the boards. And I think as industry leaders, I guess our role here is to keep having this conversation. And in my mind, again, it's the G of the ESG and it should sit up there in conversations, along with climate change and modern slavery. It's the Code, it's the practices operating within the largest financial market that we have globally. And it's there ready to go and from a buy-side perspective certainly does help level the playing field. So Guy, you might have some comments from your committees on other bottlenecks or obstacles to that buy-side take up.

Yeah. I think part of the question, as I said, is how you frame it. There are a lot of buy-side participants and what I care the most about is actually the ones who are large and have a material imprint on the market. Particularly if you're executing FX with in-house, then you're as much a market participant as anyone else.

And so I would certainly encourage those participants. But as I said earlier, I look at the top asset managers in the world, we've got more than half of them now, which is the positive way of looking at it, the other less positive way of looking at it is we haven't got the other half. One thing I do want to pick up on is a point that David made and has come through, the same point has been raised in a question is, does the limited signup by the buy-side imply disagreement with the Code or some parts of it?

And as David mentioned, I do know that he does disagree with some parts of it, but nevertheless will sign the Code. And there are other market participants who I do talk to who say that they haven't signed the Code because they don't agree with parts of it. I would say ‘last look’ is probably one of the ones which gets most frequently cited, pre-hedging's probably about on equal par with it. And I suppose it depends on which way you want to look at it. I think it's important to have a code of practice, and you may not agree with all elements and you may want to take it further than what we've got in the Code, and that's absolutely your prerogative. But absent the Code, we don't have any common standard of practice across the market and I think that's unambiguously a worse situation.

And I think the proof of that pudding potentially is in the eating, which was where we were before this and why indeed the whole work to pull the Code together came about. So we do know what the other state of the world looks like and it wasn't great. Particularly, I would say for buy-side participants, what really wasn't that great. So I accept that everyone's not going to agree with everything we've got. In the end, we've pulled this document together, as I said, across 20 jurisdictions across the whole breadth of market participants. And there are going to be things which everyone doesn't like. I have had to mediate any number of conversations between people on all sides of these arguments. And in the end, there is a degree of compromise. I think there is compromise though without watering it down to motherhood statements.

And I'd say anyone has the prerogative to take, in their practices, certainly some of the principles we have further than what we've got. I certainly wouldn't be comfortable with someone taking them less than what we've got, but you absolutely have the prerogative to take them further. The other point, I think is often where FX sits in the institution in buy-side firms. So there are some buy-side firms who has a larger market participant as any of the large sell-side, well not as a large sell-side bank but certainly any of the second tier sell-side banks. Buy-side firms who execute more volume regularly than some of those. If you're one of them, then I think you are a significant market participant and absolutely I would expect you to sign the Code. But there are other organisations where your engagement with the FX market is indirect, maybe through an execution agent or the person who actually manages your funds. In that world, I don't have so much problem in the fact that you haven't signed the Code. I think you should read it and understand how your FX business is being executed.

One of the things that when Paul Fisher and I were doing the work around the 4pm fix, we were, let me go with ‘stunned’, (I could pick a worst word, if I felt so inclined), stunned with the lack of knowledge by some very, very large institutions about the way their 4pm fix orders were handled and indeed, pretty much no knowledge and these were some very, very large firms. And often that comes from the view that, well, I'm an equity manager, or I'm a fixed income manager, and I'm not an FX person. It's like, okay, fine. But you're managing a global portfolio and FX is at least as large a risk and particularly FX execution risk as any of those execution risks within your equity portfolio or in your fixed income portfolio.

And a very good example currently is the issue around settlement risk. If you're on the other end of a settlement fail, you will notice that regardless of how that transaction is actually executed. So at the very least, if I was a buy-side participant, I'd like to understand what the issues are. If I'm running a Turkish Lira portfolio, you've got to understand settlement fails and how that goes and understand how the person who's executing the trades on your behalf, how they're handling them. So I get the point that for some organisations, FX is not a big part of their business and there I'd very much emphasise that you should read the Code and understand the parts that are relevant to you, particularly around execution. That's the part I would particularly highlight.

And I take the point that there are 55 principles and not all of them are relevant. I actually don't think it's all that hard to read. It's written in plain Australian. It's not written in ‘legalese’ and it's not so hard to read. And so I would encourage people to do that. I also understand that on the list of priorities, particularly regulatory priorities the buy-side firms are having to address, this may be a fair way down the list. Again, I absolutely understand that and again, I would just encourage people to at least read it. But if you are engaging in the FX market in any substantive way, particularly as more asset managers are bringing in FX execution in-house, then I think you've got to understand that you are insignificant market participant and this absolutely should be applied to you.

Thanks Guy. You mentioned also the review of the Code, obviously coming up, and we'll pass the three-year mark and a lot of progress has been made. Perhaps we go to David first on what you would like to see in the review, and then maybe Guy could give us a hint in terms of how he thinks this review might evolve, in terms of how extensive or is it a more iterative approach taking on board the feedback and the experience of the last three years, but over to you first David, on your wish list?

I won't give you my wish list because Guy's heard it five years ago. But look, I think one point Guy said, and you just said it yourself, right? This is an iterative process. And again, I go back to the point of engagement so that when I look at it, what I do at LMAX Group is build a lot of technology. Effectively, we're a FinTech company and quite often, if I ask my tech guys, how long does it take to build this? They'll tell me it's a year, when I need to get product out and do it before that. So we have this thing called MVP. Minimum viable product. Not most valuable player. And actually, that's the way I think Guy's just said it about the Code. If you're struggling to sign up to it, see this as the minimum viable product. Honestly, there's not a lot to disagree with.

I mean, I can disagree and I will do. I disagree with Pre-Hedging and I disagree with ‘last look’. It doesn't exist on LMAX Exchange, it cannot exist. We don't operate with ‘last look’. But that's okay because practitioners use it. People who trade on LMAX use it. But if I look at the 55 principles again,. it's the minimum viable product, it's what you should expect as a customer. So I don't know what's holding you up. In terms of the three-year review, I will have a little pop here at Guy and the GFXC, it needs to be more inclusive. At no stage have I been asked to be part of any working group. That's just a fact. Why is that? I'm the most vocal opponent of principle 11 and principle 17.

Incidentally I'm not saying I have the time or want to be part of a working group, but it's okay for the working groups themselves to allow an opposing view. FX for too long has been a closed shop. That's partly how we got there, how we got to the scandals, why we have a global code, Why we have a much more transparent market. It's not all down to the Code. The FX market today is a much better market than it was 10 years ago. It's not all down to the Code. It's down to the practitioners in it, the behaviour of the people within it. It's down to some regulations, it's down to the improvements that technology have brought. But we must have inclusivity. Does the buy-side you talk about, I hear two different numbers there. Guy says 50% of the big guns signed up. You tell me 10% overall. Okay. Has the long tail, do they feel they've been included?

Is it apparent they've been included? Have vocal opponents of a particular principle been made aware that they're included, or that their voice has been heard? Guy's predecessor, I spoke to him in an airport lounge, at Heathrow. And he told me, "‘last look’ wasn't even a topic for debate, David." And you shouldn't push your commercial models. It's not a commercial model, It's an execution model, okay? That's all it is. But it's okay to have again, to have a differing view. What I want, I'd like the next three year review is more inclusivity. I happen to believe you're going down the wrong route with standardisation around ‘last look’, because I think you're going to end up with a very long list. Right? But if it's included, if it's acceptable under the Global Code, then you're going to have a long list. Now the problem there is getting every practitioner to agree to the standardisation of those standards. For example, hold time. What's acceptable? Let's get into the minutiae of it. Invariably in the Code, you're going to say, if you agree to a hold time, it's okay. The hold time shouldn't be more than … Pick a number, a hundred milliseconds. Someone's going to say, "Well, David, I need 250 milliseconds in the Israeli Shekel, right? Maybe five years actually, but different hold times than you need in say Euro Dollar.

So then you're going to have this very wide standard. And then you go back to you want buy-side adoption. They're going to say, "Well, hold on a minute, I can't sign up to this hold time of half a second or a hundred milliseconds when I know there's good guys over there that give me zero hold time. And then you get back into the disclosures again. Guy, I know you mentioned it in your keynote. They're expansive right now, but why can't they be, for example? Why can't they be, if it's in a bilateral relationship? You sign up to the bilateral relationship, right? You agree to those terms of business. So if I was there, if I was a bank liquidity provider, I'd say these are my rules of engagement. Sign up or don't.

And my hold time would probably say, "As I see fit." And why not? So look, I think overall, I think there's some wrong turns being taken, but overall I would say inclusivity, engagement and with that inclusivity and engagement, you will get more adoption. But again, back to being a champion for the Code, I'd say to the buy-side, "See it as minimum viable product." I don't see what you have to lose if I'm honest? Because overall we will end up, we will iterate, Susan, to use your word, towards a better marketplace for all.

I take David's question. I mean, we are trying to land some text over the next couple of weeks, three or four weeks, and then get it out to the market for general feedback. We'll propagate that out around the world through the various Foreign Exchange Committees and absolutely put it there to get people's feedback on. We're trying to be as inclusive as we can be, while being workable as well. But we are certainly going to give everyone the opportunity to comment shortly. We hoped we'd have been at this point a bit earlier, but we had a pandemic come along and get a bit in the way. But we're hoping to get that material out for people shortly, to get their comment, where possible. Sorry, not where possible. We are going to get it out there shortly, between now and mid-November or so.

And there'll be more than one iteration. We will probably iterate two or three times before the middle of next year, judging on how we went last time around, particularly on some of these issues where there's a wide divergence of views. We do have a decently wide diversion of views of some of the members of the working group as well. So it isn't just people with one view, the working groups have a range of people from across the sell-side and the buy-side. But I do take David's point about trying to be as inclusive as possible, and we are trying to reach around the world. So issues like hold time are very much different, as you said, in Euro dollar. Whereas if I'm providing a quote in some of the African currencies, which get hit once every five days or so, that's a slightly different proposition.

And one of the challenges of being a global code is trying to take account of all of those different situations. And we do get quite different feedback from, say, our African representatives from the GFXC, and some of our Asian representatives, and some of our Latin American representatives than we do from our European representatives on some of these issues. So yeah, I take the fact that we haven't got a complete diversity of view, but we do aim to try and get a reasonable diversity, but we are going to give everyone the opportunity to comment more than once, hopefully starting in about a month's time or so. But I go back to what David said I think that's an interesting way of putting it, is probably a more succinct way of putting it than I have in the past in terms of minimum viable product.

This is like, as I said, as David has emphasised, you may not agree with everything, but as I said earlier, you might want to take some stuff further as LMAX does than we do in the Code, and that's fine. As long as you're shifting in that direction and not in the other direction. So I'd very much emphasise that. And I'd also emphasise that it's not desirable for people to pick and choose which principles they like and ignore principles they don't like in the negative direction. Happy for them to take them in a more stringent direction? Perfectly fine. I have no issue with that at all, but it's not a question of saying, "Well, I like this principle, but I don't like this other principle, and I'll just ignore that in my practises." So I certainly endorse what David had said about the way to think about it. I think that is a useful way to consider it.

Thanks, Guy. And probably just on that inclusivity point and I guess I speak from a standpoint of QIC being included and represented on the local FX Committee and then the Global FX Committee as well. And I would give a plug for all the resources that are available on the websites for the GFXC and as well as the local committees including meeting agendas and minutes. Certainly, in Australia, that committee list of participants is very long. I might just point out it might not be as gender diverse as we would like …

Susan, you're the one hiring the FX managers. Not me.

We did actually think about that. The execution of that is, being a global body again, this proved to be somewhat challenging in terms of the execution around that. We did actually consider that option for a while, but some of the stumbling blocks proved too big at the time. Doesn't mean we can't revisit it. Sorry, David. You were going to say?

Ah, look. I vote, yes. I discussed it with Susan previously. So yes, we should contribute. Signatories to the Code should contribute.

Yeah.

how many signatories do you have in total right now?

A bit over, we went through a thousand about two months ago.

So I mean, look. We can all do the WhatsApp type maths, but we could end up with something sizable that wouldn't be onerous for a group like us, or a group like Susan's, or some of the big asset managers you've mentioned. So I vote, yes, for one. If it comes back up again, put our tick in the box. I can't see that it would be any more onerous than some of the regulatory fees we pay every year.

Yeah. There's a related question which has come through from the audience, which maybe I can put to you, Susan. Because as I said, we've got now more … this is a bit Australian centric, but it has global relevance. There are now more buy-side participants executing FX in-house rather than relying on a fund manager to do it for them. Should more pressure be placed on the buy-side? Maybe you can put it particularly succinctly to, or does ASIC have oversight of your FX operations, given you're not the largest player in the market, but nor are you the smallest?

Yeah. So obviously we are a fund manager as well as an asset owner, but we certainly act as an external manager for a large range of clients and operate commercially, and under the regulatory regime here in Australia. And we've got APRA as well as ASIC that both have roles in this space. And as you mentioned earlier, ASIC is now taking the Code as the framework through which to regulate the FX market. So, I think there definitely is a role for those types of institutions to be asking the question, "Why haven't you signed up to the Code?" Not necessarily box ticking those who have signed up and ensuring the adherence. I think we're still at the stage where those regulators should be asking super funds, corporates, why you have not signed up to the Code. And that in turn may give us some more insights into what are the stumbling blocks. That'd be my perspective. David, you might have a perspective from Europe and the UK in terms of the buy-side take up.

I think I've said it all. I just think, get on with it. But look, I do understand their reticence, okay? Because unfortunately in capital markets, people have long memories and the lawyers have even longer memories. There's cases still coming up from seven or eight years ago. I wish you were almost able to have an amnesty. Because I don't see this Wild West that keeps coming up in the press. And invariably, you read about it and it's 2013, '14, '15. I don't see that in 2020, so maybe they've reserved their right just in case, to a point earlier. Maybe they don't have a strong enough FX desk. Maybe they've never focused on it, right? Maybe there's some litigation coming down the pipes from five years ago? So, it is difficult. I see the reticence from their legal teams, ?

"Don't forgo your rights here. Someone's going to use this against you in a court." So it might be that. So there'll be brighter legal minds than me that can tell them not to worry about that, and you don't forgo any rights. Because it's just, principle-based. There's just a bit of lethargy. And I think you're getting onto the right point there, when you get the behemoths. And by the way, Susan, I think you manage over $50 billion. So you're big enough to me. But some of the behemoths in the asset manager crowd, if you get those names in, the long tail will follow. In the UK, you've got the Investment Association. I think their strap line is something like 7 trillion under management. They will vote as a group. That's the way I see it. And you've got some big names there signing up. So the long tail will come. So I think really it's a case of getting the big names first. Genuinely, I hope they join.

One more time, Susan, I think we probably have to wrap up in a minute.

No, just very much endorse that. I mean, a lot of those resources have been put together by Stuart Simmons who runs FX for Susan. So I thank him very much for that, and put that resource up very much as an asset manager and the sort of considerations that they've gone through, QIC has gone through, in signing up for the Code. So I would encourage people to look at that material from QIC and others, which is on the website and give you some sense, here's how some of your peers have gone about it. And I very much endorse what David said. If we get the big names across the line, and we are getting more of those big names across the line, then that does set the example for others in the industry, and they can see the relevance of it.

And in the end, emphasise the point you started off with, Susan, what we are after here, the ultimate aim here, is an appropriately functioning FX market, which works for all participants. And for that to be the case, we need all participants to be following a common standard. And our aim is very much, when I think about what we have achieved is an FX global code, which does provide that standard. And as David said, at least a minimum standard, which others can take to higher levels and they absolutely have the option to do that. So let me finish there.

Right? Any final thoughts, David, before we sign off?

You can let Guy finish, to be honest. I think he said it all.

Yes.

They've done a great job.

Okay. Good talking to you both.

Thank you, Guy. Thanks David. And thank you all, listening to us. Good morning.