benchmark fixings. the gfxc drew attention to the possible consequences of these flows ahead of march quarter - end, 2 cautioning market participants to always be mindful of the impact of their transactions and to clearly understand how their orders are being handled. subsequent liaison suggested that market participants were attentive to the potential impacts. in some markets, participants looked to bring the timing of their flows forward of month - end. but while the fixings have generally proceeded smoothly, there have been occasions this year where the london 4pm fix has been associated with heightened volatility. this has prompted discussions – including amongst the gfxc and its member committees – about the fixing process. the gfxc is regularly engaging with the administrator of the w m / r fixes to relay any feedback from the committee and its members. i am encouraged by the increased engagement by them with market participants on the issues. at the same time, it remains as important as ever for users of the 4pm fix and other benchmarks 1 / 4 bis central bankers'speeches to regularly assess whether executing at those times suits their requirements. operation of fx markets more broadly, the covid lockdowns presented major operational challenges to fx market participants. these challenges were exacerbated by the market volatility, but even as market conditions stabilised, many of the operational challenges remained. however, the fx industry generally has been able to meet these challenges. a recent report issued by the gfxc summarised the experiences of both buy - side and sell - side market participants throughout this time. 3 broadly speaking, electronic trading proved effective and reliable. it is likely that the covid period will have only furthered the industry ’ s shift toward electronic trading. this includes the greater use of execution algorithms in many markets. from the gfxc ’ s perspective, the recent period has highlighted the importance of having common standards of industry practice. the abrupt change in market conditions that we witnessed this year also underscored the importance of transparency. as spreads widened, trade sizes were reduced and ‘ last look ’ rejection rates rose, clients needed to understand the implications of this for their activities. review of the fx global code while the code has certainly proven its value since it was introduced, the fx market is constantly evolving. when the code was launched in 2017, the gfxc committed to undertaking a review of the code every three years to ensure that its guidance remains appropriate and

it systems of a sophistication that undoubtedly needs a degree of scale to achieve acceptable unit costs. personally, my reading of the evidence is that a €100 billion bank is not much larger than is needed to deliver the full range of banking services at the lowest unit cost. foreign or domestically controlled? one way of achieving low unit costs is, of course, to rely on multi - national corporations in banking as we do to a large extent in the manufacturing and internationally traded nonfinancial services sector already in ireland. having foreign ownership can help absorb problems. even if some of the entrants of the early 2000s ( danske, halifax - bank of scotland, rabo ) and earlier ( royal bank of scotland, kredietbank ) – all coming from within the european union – stoked up the over - heated credit competition in the boom, they certainly also absorbed a sizable chunk of the losses in the bust. and foreign shareholders owned well over half of aib and bank of ireland when the crisis broke. ( at present, foreign shareholders hold more than 70 per cent of the equity in bank of ireland ). but what about in normal times? to what degree is it safe to rely on foreign controlled entities for delivering the full range of banking services? the international literature notes the tendency for foreign - owned banks to serve mainly large companies and wealthy individuals when they enter a banking market ; but it also emphasises that their entry can drive the incumbent banks to refocusing on smes and middle - income households, with a beneficial effect on availability and pricing of services to this clientele. perhaps then the best mix is to rely on foreign - owned concerns for those services that require large scale, while not neglecting the importance of the local relationship banking that is necessary for supporting the sme sector. internationally oriented or domestic oriented? does that mean that those banks that are, in the future, locally controlled should not be looking to export business? this is a question to which one would tend to give a different answer after the crisis than before, though maybe the centralisation of banking supervision and resolution in the euro area will change it again. looking at the experience of the icelandic banks, whose export - orientation had got to the point where over 70 per cent of their net income was said to be generated from international bis central bankers ’ speeches business, but which then spectacularly blew up destroying a sizable segment of the icelandic economy even though their foreign creditors were not bailed out by