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The practices are highlighted in a new FMSB paper or “Statement of Good Practice” on surveillance, which sets out the core principles that firms should consider and also identifies current good practice for surveillance in the foreign exchange markets.
In a separate Statement of Good Practice on conduct training in wholesale fixed income markets, the FMSB recommends that senior front office managers should play a bigger role in conduct training, making time for face-to-face discussion of conduct issues with staff.
Mark Yallop, chair of the FMSB, says: “More effective surveillance systems and better conduct training are two areas the industry needs to work on to improve conduct in wholesale fixed income markets. These statements of good practice share good or best practice in the industry but more importantly, they allow firms to measure themselves against their peers.”
Among the core principles for surveillance practice that the FMSB recommends firms consider are: ensuring the surveillance function is independent of the front office; that there is effective governance and controls; and that surveillance systems are reviewed regularly to make sure they are fit for purpose as risks change.
Yallop adds: “Firms need to keep their surveillance practices constantly under review. This is a fast-developing area and technology is having a profound impact on industry practice.”
The need for better surveillance to address market manipulation was identified by the Fair and Effective Markets Review (FEMR) which said in June 2015 that “substantial further development of firms’ misconduct surveillance is required to deliver fully effective oversight of FICC markets.”
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