The ACI Financial Markets Association (ACI FMA) is focused on providing helpful outcomes on the future direction of the regulation of conduct oversight and education in the wholesale markets industry. In response to the FEMR Consultation under the Bank of England, the ACI and its many international members have received the endorsement to our Model Code from many large UK-based institutions, the European Central Bank’s FX Contact Group, the Reserve Bank of Australia’s FX Committee, and elsewhere. In fact, Code of conduct compliance is an FSB requirement! The ACI FMA has devised the e-Learning and Certification Portal to provide a way of helping bank deal with the plethora of conduct issues. Our work is having European-wide, but also global influence and impact. There is indeed tremendous value in ACI FMA’s articulated strategy of building a relevant educational and certification tool for global distribution.
As such, I welcome the opportunity to discuss this in person, and review how we might be able to help you prepare for the future.
We have provided a brief update on the progress we have made to some of the new Single Code leadership, and the FEMR team at the Bank of England. We are making preparations for partnering with the major market players on conduct after the release of the FEMR report, which is out by the time you read this. We hope that you are encouraged by the following information:
1) The ELAC portal is being deployed to early adopters and market participants of an industry seeking a mutual code adherence tool. I am proud that we have taken the responsible decision to make conduct training and adherence accessible, and to have provided leadership and opportunity for this to take place in short order. We have now demonstrated the ELAC Portal to nearly 90 institutions, and overwhelming response has been one of support and interest. We even have our first “clients”, including two central banks, with many new subscribers in the wings. There are many more yet to come. Your Markets team would be welcome leaders/early adopters in this.
2) The Portal has been designed to be entirely “code agnostic”, meaning that while the current content is based largely on the international ACI Model Code, it is flexible in format and design to enable its applicability to any code. This means that individual banks can use this tool for their private corporate benefit.
More interestingly, the Portal is readily adaptable and designed to facilitate the inputs from any source. The means that the work emerging from FEMR and the BIS Single Code process can be ported onto the tool.
We can provide this as a substantial mechanism to rapidly deploy conduct training to all users. Further, it can be used to enhance the market’s ability to teach, test, reinforce and monitor knowledge of codes of conduct. We could potentially be used across other subjects too, but this is not our goal now.
3) The success of this effort will be determined by market participants understanding of the importance of such work. As the broad array of FEMR work becomes embedded in practice in the UK, critical areas such as conduct and adherence can be rapidly expanded globally via the internationally nature of the ELAC Portal. This adds value to your work through rapid delivery. Our decision to focus our efforts in ways that support this fundamental theme of market best practice and ethical behaviour remains at the heart of the ACI FMA’s mission, but more importantly, is enabling leadership in this area for us all.
We can, as you rightly say, help save the industry and all participants a huge wasted effort by joining forces on this, getting it right, and deploying a common platform. The sooner, the better (cheaper, more efficient, more effective) for everyone.
Frankly speaking, we are finding a lot of support for the manner in which we are helping banks to save money, redefine the conduct training along industry lines, and having you at the table would be mutually beneficial.
Can we arrange to meet with your relevant people on this subject, please?
By reviewing and supporting the ACI ELAC Portal, you give yourself and your organisation a head-start in mitigating conduct risks via education and attestation, and provides a strong ethical platform upon which you can move forward with your businesses. I can provide far more detail in person.