FXPA – A new force for advancing the interests of the FX Industry – By Adam Cooper, Chair, FXPA

The FX market stands at a critical juncture as technological innovation, new competitive forces, and an evolving market structure and regulatory framework redefine the FX landscape. While financial market regulatory reforms introduced in the wake of the financial crisis generally did not encompass the FX market, new requirements have and will be applied to certain FX activities.
More recently, investigations and settlements related to the alleged manipulation of benchmark FX rates have heightened public scrutiny of the FX marketplace. Against this collective backdrop, the Foreign Exchange Professionals Association (FXPA) was formed by a diverse group of FX market participants to provide a unique contribution to the public dialogue.

OFFICIALLY LAUNCHED
After a series of meetings that began in January 2014, the FXPA officially launched on September 25, 2014. Based in Washington, DC, FXPA’s aim is to engage key US and international regulators, policymakers, the general public and news media, through a combination of education, research and advocacy to advance a sound, liquid, transparent and competitive global currency market.
Diversity of membership is embedded into FXPA’s organizational construct to ensure wide representation of the professional FX market. Founding members epitomize this diversity – including the buy-side, exchanges, clearing houses, trading platforms (SEFs/MTFs), technology companies, banks and non-bank market participants. FXPA launched with membership from The Bank of New York Mellon, CalPERs, Campbell & Company, Citadel LLC, CME Group, GFI Group, LCH.Clearnet, LMAX Exchange, Traiana and Virtu Financial. Since launch, Bloomberg Tradebook, Cürex, FastMatch, NASDAQ and Singapore Exchange (SGX) have joined as founding members.
The FXPA’s initial Board of Directors, comprised of Founders’ Council Members, is leading the organization in formulating its initial policy objectives and building a diverse membership, among other areas of development. Ultimately, the FXPA Board will include participation from the full spectrum of institutional FX market participants.
The Board of Directors is supported by a series of committees, which are open to all members. Each committee will focus on specific industry areas (i.e., operations, legal and compliance, membership, technology, media relations, market structure), and will report to the Board of Directors.
In addition to myself, the initial Executive Committee that was elected in September includes Derek Sammann, Senior Managing Director, Global Head of Commodity and Options Products, CME Group as Vice Chair; Craig Messinger, Executive Vice President, Global Head of Trading and Risk for Foreign Exchange, Derivatives, Fixed Income and Equities at BNY Mellon Global Markets, as Treasurer; and Eric Busay, Portfolio Manager, CalPERS as Secretary.
The initial Board members, in addition to the four officers, include Patrick Bartle, Global Head of FX Strategy, LMAX Exchange; Kevin Cudahy, Director, Bloomberg Tradebook Services; Dmitri Galinov, CEO, FastMatch; David Holcombe, Head of FX Product, NASDAQ; Mark Sandomeno, Manager, GFI Emerging Markets, GFI Group; John Shay, Partner – Transaction and Technology Services, Virtu Financial; Gavin Wells, Global Head of CDSClear & ForexClear, LCH.Clearnet; Jamie Singleton, Chairman and CEO, Cürex; and Michael Syn, Executive Vice President, Derivatives, Singapore Exchange (SGX).
ONE VOICE
FX is a massive, global market with deep liquidity that has always been largely independent. However, 18 months ago regulators alleged that the 4pm Fix may have been manipulated. The Financial Stability Board recently issued a report aimed at repairing the reputation of an industry struggling with accusations of collusion around the FX closing rate with recommendations aimed at market reforms, including: the calculation methodology of the WM/Reuters 4pm London benchmark rate; recommendations from an International Organisation ¬¬¬¬of Securities Commissions (Iosco) review of the WM 4pm Fix; the publication of reference rates by central banks; market infrastructure in relation to the execution of fixing trades; and the behaviour of market participants around the time of the major FX benchmarks (primarily the 4pm Fix). Recent settlements have been agreed and hopefully this shadow over the industry is on its way to being lifted.
Meanwhile, outstanding issues such as proposals to require the clearing of Non-Deliverable Forwards (NDFs) show that the entire FX industry, speaking as one, needs to come together and make itself heard with a voice that includes all parties involved in an FX transaction – buyer, seller, technology provider and trading venue, among others.
Until now, the FX industry lacked an association that truly represented all aspects of the industry; one that also advocates on behalf of the full spectrum of the FX market – something that seems surprising given that the wholesale FX market turns over in excess of $5 trillion per day, largely on an over-the-counter (OTC) basis, nearly 24/7, around the world through a multitude of trading avenues – from electronic to voice.
There are of course a number of important bodies that actively work to enhance the operation of the FX industry and we aim to work closely with these groups to coordinate our collective efforts. The FX committees connected to key central banks around the world perform vital functions in producing guidelines and recommendations around a myriad of market conventions, on a country by country basis. More recently, the GFMA introduced a Global FX Division, which performs an essential function by advocating on behalf of its bank members. Meanwhile, ACI – The Financial Markets Association has done significant work in the areas of ethics guidelines, arbitration and educational initiatives for the FX industry.
UNIQUE POSITION
As this new association will be based in a global policy capital, FXPA is in a unique position to educate and communicate the interests of the industry with lawmakers and regulators in Washington and globally. Because our members recognized the regulatory focus on the FX market will only intensify, we felt the time to act was now. By creating and maintaining a permanent presence in Washington, we can ensure that FXPA is a part of the policy debate and has a seat at the table with other important thought leaders globally.
With a primary objective of educating regulators and policymakers through written and in-person communications, the FXPA will consider such issues as Global FX Market Regulation; Execution Quality; Benchmark Rates; Post- Trade Reporting; Risk Controls (and Best Practices); and Clearing of NDFs, amongst other important topics.
Within our first two weeks in operation, FXPA formed an NDF working group, and issued two statements around the FSB’s final report on Foreign Exchange benchmarks and the CFTC’s consideration of a clearing requirement for NDFs. On November 6, FXPA submitted a formal response to ESMA’s consultation paper on a clearing obligation for NDFs with recommendations that the group’s wide ranging membership collectively viewed as fundamental to ESMA’s further policy development.
As technological innovation, new competitive forces, and an evolving regulatory framework redefine the FX landscape, we must promote a market structure that fosters a robust, efficient and transparent market for all participants. FX is a cornerstone to our capital markets, and the FXPA is the ideal vehicle to strengthen collaboration across the industry and engage with policymakers to achieve these shared objectives.