market - based adherence comes through the fxcs. the global fxcs issued a joint statement of support at the launch of the code in new york as well as stating their intention to make adherence to the code a likely requirement of fxc membership. 7 in australia, a commitment to adhere to the code will be a requirement for membership of the afxc. that would ensure the code is embedded at the core of the fx market, but it is also important that it extends beyond that, and that there is, at the very least, an awareness of it across all market participants. a second dimension of adherence is that the bis central banks have signalled their commitment by announcing that they themselves will follow the code, and that they expect that their counterparties will do so too. 8 to that end, the rba will no longer transact in the fx market with those that don ’ t commit to adhere to the code. a third dimension of adherence is that we are talking to regulators in our various jurisdictions as to how they might use the code in monitoring market conduct. in australia, the securities regulator, asic, is very supportive of the development of the code and is considering how it might utilise the code in its market surveillance. in its recent enforceable undertakings against some local market participants, asic has referred explicitly to the code. asic ‘ encourages market participants to adhere to high standards of market practice, including those set out in the global code ’. 9 in the uk, the financial conduct authority ( fca ) is considering how they might incorporate the code in the senior managers regime there. given that we are only providing the full text of the code to the market in may, there will be a period of time for market participants to adjust their practices where necessary to be in line with the principles in the code. hopefully not much time should be required to do this. this period of time might potentially be as short as six months, but no more than twelve months for the vast majority of market participants. how much effort this might require will in part depend on the nature and extent of your engagement with the fx market. in drafting the code, we have always kept the principle of proportionality at front of mind. conclusion we are on track to complete the code so that it will be released in london in may. at the end of that process, for the code to be effective and for it to achieve what we want it to achieve, it will need to be

can reasonably expect from your counterparty as you transact your fx business. what this means in practice is that the steps different market participants take to align their activities with the principles of the code will necessarily reflect the size, complexity, type and extent of their engagement with the fx market. as i mentioned earlier, the first phase of the code was released in may 2016. it covered areas such as ethics, information sharing, aspects of execution and confirmation and settlement. the second phase covers further aspects of execution including e - trading and platforms, prime brokerage, as well as governance, and risk management and compliance. we have provided market participants with a number of opportunities to comment on the code, in addition to receiving the direct input of the market participants group led by david puth. over the past few months, drafts of the full text of the code have been distributed to market participants for their review, principally through the various fxcs, but also through other industry associations to ensure all perspectives are appropriately reflected in the code. through this process, quite a few thousand comments were received. in my view, the text of the code provides the best and most appropriate guidance we could give, given the sometimes wide range of feedback received, particularly on those small number of issues that are most controversial in the market. the most obvious example of this is ‘ last look ’. this issue has generated considerable passionate discussion. i would expect that discussion to continue after the release of the code in may and that the code might evolve as a function of that discussion. i would like to make the point that if market participants think it would be preferable for the code to have gone further, they are welcome to go down that path in their operations. on the other hand, it would not be desirable for the converse to occur, namely for market participants practices to fall short of the principles described in the code. that said, i think it is a good outcome of the process that we were able to distil the points of contention down to a small number of ( not insignificant ) issues. outside of a small number of contentious areas, the feedback was reflective of a widely held consensus. market participants have recognised the code ’ s aim of helping move the fx market to a better place. i will illustrate that with a couple of the areas that were addressed in the first phase of the code, which is already in the public domain. one example of this is around information sharing, where many market participants highlighted that they are unsure