Minutes of the UK Money Markets Code Sub-Committee – November 2021

Time: 2pm – 3.30pm 16 November 2021 | Location: Bank of England, Moorgate Offices


Item 1 – Introduction and welcome to new members

The Co-Chairs welcomed everyone to the Bank, in particular, the new members of the Committee: Malvi Ruparelia (Barclays Capital), John Edwards (CME Group), Antony Baldwin (LCH), Andrew Welch (LGIM), Bola Tobun (London Borough of Enfield) and James McKerrow (Insight Investment).

Item 2 – Terms of Reference

The Committee agreed the draft Terms of Reference (ToR) with one exception. One member noted that the draft ToR did not include wording on Diversity and Inclusion. It was agreed that the final (published) version should include wording on the Diversity and Inclusion. For consistency it was agreed that the wording could be taken from the ToR of the Securities Lending Committee.

Item 3 – Objectives and aims of the UK Money Market Code Sub-Committee

The Co-Chairs set out their objectives for the Code Sub-Committee stating that they wanted it to be inclusive and dynamic. The Co-Chairs also stated their preference for keeping the Code up-to date against the backdrop of the rapid pace of change in sterling money markets. This could take the form of regular (informal) reviews and updates to the Code via the Explanatory Note of the Code and citing examples of best and poor practice. The Code could then be revised formally at the 3 year point as stated in the Terms of Reference. The Co-Chairs were also open to the idea of experts being invited to speak to the Code Sub-Committee for example about new products. There was a question about whether the Code should include in scope retail investors. It was noted that the Code is aimed at wholesale activity and so captures retail brokers but not the underlying customer.

Item 4 – Initiatives for promoting the UK Money Market Code – Local Authorities, Corporates and Hedge Funds through the Alternative Investment Management Association (AIMA)

The Committee was provided with an update on some of the activities that have been undertaken to promote that Code since the last Sub-Committee meeting. Presentations on the Code have been given at fora held by the London Borough of Treasurers and the Chartered Institute of Public Finance and Accountancy (CIPFA). CIPFA asked for a one-page summary of the Code to circulate to their members. The Committee thought that having a one-page summary of the Code would be a good way to promote the Code more widely. With regards to promotion of the Code, the Committee queried why the treasury advisors of Local Authorities were not promoting the Code amongst their clients. The Committee also queried whether, as an alternative to signing the Statement of Commitment to the Code, Local Authorities could demonstrate adherence to the Code. It was noted by a member of the Committee that Local Authorities could potentially include a reference in their policies that shows their compliance to the Code.

The Committee noted that the Alternative Investment Management Association (AIMA), have suggested that Hedge Funds have historically been reluctant to sign the Code, as they felt it was not applicable to them. The Committee felt it was appropriate to revisit the issue of engagement with this sector. The production of a one page summary of the Code was seen as a first step in engaging with Hedge Funds. There was also a discussion about the promotion of the Code through the work that AIMA does. The Committee felt that any promotion strategy should revolve around demonstrating how AIMA members benefit from signing the Code. In terms of promoting the Code more widely, the Committee suggested promoting the Code at conferences, pushing the one-pager out through social media and blogs and writing an article in the Association of Corporate Treasurer (ACT) magazine. It was also noted that the International Securities Lending Association had started a process of mapping best practice in their guides to elements of the Code.

Item 5 – Engagement with ACI Training

The Committee were asked whether there were any objections to engaging more with the ACI in regard to training (currently the only body that provides training on the Code). The Committee would like to see other companies provide training on the Code. The Committee agreed to engage with the ACI; one member of the Committee suggested they could provide the name of an additional training supplier. It was noted that the Chartered Institute for Securities and Investment (CISI) had referenced the UK Money Market Code in their curriculum.

Item 6 – Update on the Global Foreign Exchange Code

The Committee was updated on the three-year review of the Global Foreign Exchange Code (GFXC) which was launched in December 2019 and completed in August 2021. Of particular note to the Committee was the publication of Guidance papers on ‘Last Look’ and ‘Pre-Hedging’. It was agreed that the UK Money Market could benefit from guidance on issues such as settlement efficiency and good settlement practice as detailed in the GFXC. This could be addressed in the Explanatory Note.

Item 7 – Diversity and Inclusion

Following the publication of the UK Money Market Code which highlighted the importance and benefits of diverse and inclusive money market participants’ teams, members of the Committee were encouraged to invite diverse members of their respective teams to Sub-Committee meetings. These had been held virtually due to the COVID-19 crisis. Given the transition to in-person meetings and the capacity constraints that this brings, the Committee was asked whether the aforementioned practice should be continued. It was suggested that the Secretariat ask members to bring their colleagues to Committee meetings on a rotational basis. One member of the Committee suggested sending a member of their team to the meeting if they are unable to attend. The Committee agreed with the proposal.

Item 8 – Environmental, Social and Governance (ESG)

Given the complexities around ESG issues, members felt the Code should be looking to provide more guidance in this space in the not too distant future.

Item 9 – AOB

Committee attendees

Attendees (in person)

Malvi Ruparelia – Barclays Capital

Ina Budh-Raja (Co-Chair) – BNY Mellon

Glenn Handley (Co-Chair) – HSBC

Veronica Iommi – IMMFA

James McKerrow – Insight Investment

Andy Dyson – ISLA

Antony Baldwin – LCH

Mark Thomasson – Natwest

Attendees (remotely)

Gordon Lowson – Aberdeen Standard Investments

James Winterton – ACT

Alessandro Cozzani – BOFA Merrill Lynch

Tim McLeod – Blackrock

John Edwards – CME Group

Jessica Pulay – DMO (Observer)

James Eldridge – FCA (Observer)

Oliver Clark – FMSB MTS (Observer)

Vicky Worsfield – Guildford Borough Council

Andrew Welch – LGIM

Terry Barton – Nationwide

Nic Erevik – Newcastle Building Society

Philip Chilvers – TP ICAP


Bola Tobun – London Borough of Enfield

Jennifer Keser – Tradeweb

Bank of England

Jon Pyzer

Edward Kent

Kpakpo Brown (Secretary)


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