Hiroshi Nakaso: Developing a global code of conduct for the foreign
exchange market
Opening remarks by Mr Hiroshi Nakaso, Deputy Governor of the Bank of Japan, at the BIS
FXWG-MPG meeting, Tokyo, 26 February 2016.
* * *
I. Introduction
It is a great pleasure to welcome the BIS FXWG (Foreign Exchange Working Group) and MPG
(Market Participants Group) joint meeting on developing a single global code of conduct for
the foreign exchange market.1
In March last year, the eight foreign exchange committees in the major financial centers
gathered here in Tokyo and adopted the "Global Preamble,"2 sharing their commitment to
developing and promoting clear, robust, and implementable best-practice guidance in the
foreign exchange market. Building on the Global Preamble, in May last year, the BIS governors
agreed to set up a working group to facilitate the establishment of a single global code of
conduct for the foreign exchange market. Since its inception, 16 central banks and more than
30 private-sector professionals from around the world have been participating actively in this
project. Without a doubt, this project is a cornerstone for the ongoing global initiatives to
address the misconduct issues in the broad financial market. Thanks to the hard work of each
member and the excellent leadership of the Chair, Guy Debelle, significant progress has been
made with the first public update, which is envisaged in May 2016. As a member of the FXWG,
the Bank of Japan is honored to host this joint meeting with the MPG today.
In my remarks, first I would like to share my views on why we need the global code and how it
matters to the central banks, and then express my support on key concepts of the code that
have been shared among our colleagues here.
II. Why we need the global code
Let me begin with my thoughts on how the global code can contribute to the sound functioning
of the foreign exchange market.
It has been broadly agreed that the single global code of conduct for the foreign exchange
market aims to promote a robust, fair, liquid, open, and transparent market. Achieving this goal
is crucial to the sound functioning and development of the foreign exchange market.
Why is a well-functioning foreign exchange market highly important from a central bank's
perspective? We closely monitor the financial market developments when conducting our
policy in pursuit of price and financial stability. Financial markets carry crucial information
regarding market participants' views on economic and financial conditions, and also play a vital
role for transmission of our policy. Financial markets must be functioning effectively to play
such important roles.
A well-functioning market needs to be supported by sufficient market liquidity. Therefore, I
strongly believe that the central banks should continue to be committed to enhancing market
liquidity as part of our efforts to develop the code. According to the widely accepted definition
of the BIS, "A liquid market is a market where participants can rapidly execute large-volume
transactions with a small impact on prices."3 I believe that a robust, fair, open, and transparent
market, where diverse types of participants with diverse business models can confidently
transact will indeed support market liquidity, which in turn enhances the functioning of the
foreign exchange market.
III. Key concepts of the global code
Next, I would like to touch upon a few key concepts of the global code that have been shared
among our colleagues here. I would like to express my strong support for these concepts, as
they are crucial to improve market functioning.
A. Principle-based code
The first key concept is that the global code will become most effective when it is
principlebased, taking into account the diversity of market participants.
The foreign exchange market is a large cross-border market uniquely featured with diverse
participants. Indeed, we cannot find any other market where such a wide variety of financial
and nonfinancial corporations transact on a daily basis. Over-the-counter (OTC) transactions
prevail, and the electronic trading venues are also diverse, ranging from brokers to single- and
multiple-dealer platforms. Regulatory settings covering foreign exchange transactions are also
diverse in a range of jurisdictions.
A principle-based approach, rather than a prescriptive rule-based approach, is well suited to
address such a diversity of participants and a complexity in market structures across the globe.
Regarding the approach, Guy Debelle raised an important point in his speech last November,
and let me repeat it here: History has shown that "the more prescriptive it becomes the easier
it is to get around [because] rules are easier to arbitrage than principles."4 I fully support his
views.
B. Collaboration between the public sector and the private sector
The second key concept of the global code is that continuous collaboration between the public
sector and the private sector is indispensable.
The foreign exchange market has evolved through close collaboration between the public and
private sectors. For example, the foreign exchange committees in the major financial centers
typically comprise both central bankers and private-sector participants.
Work on the global code has also achieved progress through a public sector-private sector
partnership. The MPG, which consists of both sell-side and buy-side institutions, has been
providing valuable insight based on its members' expertise in market practices and innovation.
It would be desirable that innovations led by the private sector continue to evolve under the
appropriate code of conduct, thereby improving market functioning. The public sector should
endeavor to align the private sector's incentives appropriately to support further market
innovation and sound functioning of the foreign exchange market.
C. User-friendliness
The third key concept is that the global code should be succinct, clear, and easy to use. The
code becomes valuable only when market participants make good use of and adhere to it in
their day-to-day business at the practical level.
In addition, bearing in mind the existence of diverse participants and diverse business models,
I would like to emphasize the importance of clearly addressing what market participants can
do under the code. This is to prevent over-cautious behavior of market participants which could
be detrimental to fostering well-functioning markets. As an initiative to enhance market
functioning through clearer dialogue among market participants, the Tokyo Foreign Exchange
Market Committee developed the "Tokyo Blue Book" in April last year.5 The book provides
guidance with succinct, clear statements and practical examples to help promote
understanding of the code among Tokyo market participants.
IV. Concluding remarks
I firmly believe that the successful development of a single global code and greater adherence
to it will reinforce the functioning of the foreign exchange market and facilitate vibrant, sound
development of the market. The Bank of Japan has been, and will continue to fully support and
be committed to the work of the global code. I am confident that this Tokyo meeting will provide
us with a valuable opportunity to achieve further progress in our work.
Thank you very much for your kind attention.