. but to set a higher requirement if we have doubts about : the home resolution strategy, the availability of a surplus at the top of the group or a lack of reciprocity in mrel - setting in other jurisdictions ( that is others all set at the 90 % end of the range ). we expect to say more about surplus mrel and the form it should be held in to be readily available when we come to finalise our internal mrel policy next year. another important objective for us in setting policy on internal mrel is to avoid any distortion in the sequence of loss absorption between operating companies ( opco ) and the group holding company ( holdco ). we require uk banks to issue external mrel out of their holdcos, structurally subordinated to liabilities at the opco. the issuance proceeds are then onlent to the opco as internal mrel broadly mirroring their external form, for example : tier 2 could be onlent as tier 2, at1 as at1 and senior debt out of holdco would be downstreamed as an internal debt instrument sitting senior to capital instruments but junior to operating liabilities in the opco. we need to be sure that as losses are incurred in the operating company they are absorbed in an order that follows the opco creditor hierarchy and does not bypass certain instruments. the aim with a single point of our starting point for calibrating internal mrel for ring - fenced bank sub - groups would be 90 %, with the possibility that this could be scaled down if there are sufficient readily deployable resources. all speeches are available online at www. bankofengland. co. uk / speeches entry bail - in strategy, as the name suggests, is only to put one entity at the top of the group into resolution, preferably a holding company which is only used for issuing capital instruments to the market and otherwise has no or limited operating liabilities. write down or conversion of internal mrel instruments via contractual triggers will then allow operating companies lower down the group to be recapitalised automatically without putting them into resolution. but legacy non - equity capital instruments in opcos without the requisite contractual triggers could cut across this. we do not want these to be spared bearing losses for want of a trigger. and so, we are clear that such instruments should not count as mrel beyond 31 december 2021 and if not matured by then we will work with firms to remove them if they represent a barrier to the

collective participation in fx markets. and that is where we need more of you sign up to the global code. i mentioned earlier that there were over 950 public commitments to the code on the global index. but only 85 of those are from the buyside – and only a handful more represent platform, infrastructure or technology operators ( chart 6 ). the gfxc has recognised some of the practical challenges faced by smaller firms when signing up to the code, and has prepared new material to help ease this process. 17 but we need more of the largest firms too : 17 of the largest 30 global asset managers are still not signed up ( table 2 ). that ’ s $ 22 trillion of investors ’ funds without a voice in the use and development of the code. chart 6 : public commitments to the fx global code18 source : global index of public registers as of 9 september. signing up to the foreign exchange global code should be high on the agenda for the ceo of every major asset management firm. it deepens trust : between you and your clients, your counterparties and your regulators. it strengthens corporate governance : providing a ready - made blueprint for best practice within your firm. that is especially true for uk firms, which will fall under the senior managers regime from the end of 2019. behaviour that is in line with the code will tend to indicate a person subject to the regime is meeting their obligation to observe'proper standards of market conduct.'and the code empowers your trading teams to demand the best from others in the market, even – or perhaps especially – when fx is not your core business. all of that means a stronger foreign exchange market. but it also means better returns for your investors – so it ’ s good for the bottom line. https : / / www. globalfxc. org / education. htm? m = 71 % 7c433 ‘ buy - side ’ category includes : asset managers, corporate treasury departments, pension funds, insurance companies, quasisovereign or supranational institutions, and sovereign wealth funds. all speeches are available online at www. bankofengland. co. uk / news / speeches conclusions let me conclude. in many ways, the fx market is in great shape. it ’ s informationally efficient, resilient, and a cauldron of technological innovation. that technology is bringing many new benefits : wider access, cheaper prices, better services. but we need to ensure those benefits