The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.
Date: 16 November 2021
Time: 3pm – 5pm | Location: Bank of England Offices and Video meeting
The minutes of the meeting of 14 September 2021 were approved. Ferdisha Snagg from Cleary Gottlieb Steen & Hamilton LLP spoke about the Standardised Approach for Measuring Counterparty Credit Risk (SA-CCR). She explained that the SA-CCR, which was implemented in the EU via CRR II, is a measurement of counterparty credit risk that calculates the exposure at default of OTC derivatives, exchange-traded derivatives, and long settlement transactions. Ferdisha explained that the SA-CCR replaces both the Current Exposure Method and the Standardised Method in the capital framework and removes the Internal Model Method shortcut method from the Basel Capital adequacy framework. Ferdisha went on to detail how to calculate exposure at default under the SA-CCR and to summarise specific FX considerations with regards to SA-CCR. Kate Sumpter and John Budd from Allen & Overy LLP discussed the operational resilience requirements to which firms are subject, including Principle 3 of the FCA’s Principles for Businesses, rules in SYSC (Senior Management Arrangements, Systems and Controls), and Principles 32 and 33 of the FX Global Code and new rules published by the PRA and FCA in March 2021 which supplement existing operational resilience requirements. Both outlined the firms in scope of the rules including clarification from the FCA on the applicability to third country branches. John and Kate went on to summarise the steps required of firms under the new regime, including the need to identify important business services, setting impact tolerance and to carry out scenario testing. Furthermore, John and Kate outlined key definitions, including the FCA’s definition of client and the implications this has on FX activity. Dates for the 2022 FXJSC meetings will be announced in due course. Sharon Blackman (Chair) - Citigroup Jonathan Grant (Secretary) - Bank of England Simon Goldsworthy - Deutsche Bank David Harris - Financial Conduct Authority (FCA) Tamsin Rolls - JP Morgan Baljit Saini - NatWest Rakesh Shah - Standard Chartered Simon Helm - TP ICAP Nasia Pachiti Pallikaropoulou – Barclays Diane Bouwmeester – London Stock Exchange Group Gaynor Wood – CLS Harkamal Atwal – HSBC Zara Coe – Bank of England Matthew Hartley – Bank of England Jeremy Pitblado – Bank of England Ferdisha Snagg - Cleary Gottlieb Steen & Hamilton LLP Kate Sumpter– Allen & Overy LLP John Budd – Allen & Overy LLP Dan Parker - Goldman Sachs Nimisha Kanabar - Morgan Stanley Richard Lamb - UBS Sunil Samani - XTX Markets Jateen Shah - Bank of AmericaMinutes
Minute 1 – Introduction and Minutes
Minute 2 – Discussion on SA-CCR
Minute 3 – Operational resilience
Minute 4 - Any other business
Attendees
FXJSC Legal Sub-Committee Secretariat
Guest attendees
Apologies
