Disclosure Cover Sheets

The Global Foreign Exchange Committee (GFXC) has developed Disclosure Cover Sheets (Cover Sheets) to improve the accessibility and clarity of existing disclosures, and to support Market Participants in meeting the range of disclosure and transparency principles within the Code (last update: July 2021). Cover Sheets are meant to act as good foundations upon which Market Participants can have additional bilateral discussions where greater clarity or detail on a firm’s disclosures is required. Cover Sheets should not be used in place of more detailed disclosures and do not introduce disclosure requirements over and above what is in the Code.

To facilitate the publication of Cover Sheets, the GFXC is working with operators of Public Registers to allow Market Participants to publish a completed Cover Sheet alongside their Statement of Commitment. It is anticipated that Market Participants will be able to publish Cover Sheets onto Public Registers by end-2021. Detailed FAQs on the purpose of Cover Sheets and how they should be used are provided at the bottom of this page.

Noting the diverse array of participants who engage in the FX market, the GFXC has designed separate Liquidity Provider and Multi-dealer Platform Disclosure Cover Sheets. This reflects their different focuses and operating models. The GFXC may develop Cover Sheets for further sections of the market in future, if relevant and supportive of the disclosure and transparency landscape. All Market Participants are encouraged to review the two templates below, alongside the instructions and FAQs, to understand how and when to use Cover Sheets.

Frequently Asked Questions

Purpose and benefits of Cover Sheets

The Code is a set of global principles of good practice in the foreign exchange market. It contains 55 principles that provide a common set of guidelines to promote the integrity and effective functioning of the wholesale foreign exchange market. The principles cover ethics, governance, execution, information sharing, risk management and compliance as well as confirmation and settlement. The Code does not impose legal or regulatory obligations on market participants, nor does it substitute for regulation. It is intended to serve as a supplement to any and all local laws, rules and regulations by identifying global good practices and processes.

Cover Sheets should be used by Market Participants to locate and navigate the information they require from LPs and Platforms to make informed decisions about the nature, impact and risks of interacting with these entities. They are intended to provide greater consistency, ease of cross-reference with the Principles of the Code, and the ability to compare across different firms’ disclosures. They do not introduce disclosure requirements over and above what is in the Code. Owners of the Cover Sheets are encouraged to make them available alongside their Statement of Commitment on Public Registers.

Market Participants looking to complete a Cover Sheet in the second half of 2021 can contact the GFXC to ask for example Cover Sheets and for support – email@globalfxc.org. From 2022, Cover Sheets completed by Market Participants will be available on the Global Index of Public Registers and can be viewed as examples.

Completing a Cover Sheet

No. Completion of a Cover Sheet is voluntary.

The length of time taken to complete a Cover Sheet will depend on the complexity of the Market Participant’s business and the number of internal checks the Market Participant wishes to undertake. Based on a pilot exercise, a broad guideline would be that a Cover Sheet should take less than one month to complete (although that timeframe may lengthen or shorten as a function of the complexity of the Market Participant’s operating model and the desired Governance process). In light of the three-year review of the Code, Market Participants may wish to renew their Statement of Commitment to the Code alongside completion of a Cover Sheet.

Cover Sheets have been designed to provide additional clarity around key disclosure topics, while also endeavouring to respect the diverse business and operating models of FX Market Participants. Cover Sheets are not designed to replace a firm’s existing suite of disclosures, but instead aim to complete two primary objectives:

  1. Cover Sheets take an important step in standardising disclosures, increasing comparability and transparency; and
  2. Cover Sheets provide a useful “point of access/entry” to help Market Participants navigate the disclosure landscape of the relevant LP or Platform. They bring together relevant disclosures on key topics covered in the Code, allowing Market Participants to access, with ease, the disclosure documentation they need to make informed decisions.

There is no requirement that the entities signing the Statement of Commitment and completing the Cover Sheet are always the same. However, if the entities are different, it is recommended that the Cover Sheet clearly state that the entities are different, and list the entities to which the Cover Sheet relates.

Cover Sheets aim to reflect the diverse business and operating models of LPs and Platforms – consequently it endeavours to strike the right balance between standardised answers in the shape of “drop-down” boxes and free-form text boxes where additional clarifying commentary is required to capture the business model of the Market Participant in question. If you feel the drop-down boxes do not fully capture the operating model the Market Participant in question deploys in their business, then the free-form text boxes should be used to provide the necessary clarification to capture the nuance of the operating model. This may also include sharing helpful links to additional relevant disclosures that improve transparency and understanding of how the Market Participant operates and interacts with other Market Participants.

Unless otherwise stated, all terms used in the Cover Sheets are as defined in the Code. For terms not defined in the Code their definitions are provided within the Cover Sheets and their instructions.

Publication and Review

In the interests of ensuring that disclosures stay current and relevant, it is recommended that Market Participants who choose to complete and publish a Cover Sheet review them with adequate frequency. Practically, this will involve updating the Cover Sheet;

  • Whenever there is a material change to the Code which requires a Market Participant’s Cover Sheet to be amended;
  • Whenever there is a material change to a Market Participant’s business or operating model which equally warrants amendment to the Cover Sheet; or
  • Absent the above two scenarios, an annual review of the Cover Sheet would be considered good business practise.

Cover Sheets can be used by Market Participants in a variety of ways. The GFXC encourages LPs and Platforms that have completed a Cover Sheet to publish them publicly on their websites and on a Public Register. The GFXC is working with operators of Public Registers to allow Market Participants to publish a completed Cover Sheet alongside their Statement of Commitment. It is anticipated that Market Participants will be able to publish Cover Sheets on Public Registers by end-2021.

Alternatively, Market Participants may choose to only provide Cover Sheets on a bilateral basis, when requested by a client or counterparty. It is ultimately up to the Market Participant whether they wish to complete a Cover Sheet, and how they then wish to share it.

Market Participants are not required to make all their disclosures public, and it is acceptable to provide links to non-public disclosure materials in the Cover Sheet. There is no expectation that every document is made available to everyone, as certain disclosure documents or transparency agreements are best exchanged bilaterally (particularly if sensitive information or financial terms are contained in them, which would not be appropriate to disclose outside the parties that are privy to the document or agreement).

If you have any views on the Cover Sheets, or questions on how to complete them you can contact the GFXC at email@globalfxc.org.