Transforming data collection – Reporting Transformation Committee minutes – October 2021

Date of meeting: 20 October 2021
Location: This meeting took place via video/audio link


Item 1 – Introduction

AM welcomed all to the meeting and recapped the actions from the previous meeting (approval of the September minutes; approval of the updated Terms of Reference). The Committee confirmed its approval of the minutes.

Item 2 – Project Plan

AB presented the current progress of the project plan – the project is on track. Form DQ discovery is ending and its alpha phase is beginning. Discovery work on the CRE and Financial Resilience Survey use cases is ongoing. The programme team has added a workstream on Common Services to the project plan. The Common Services workstream will look to identify solutions and services that it plans to scale across use cases.

Key Discussion Points/Comments:

  • KP asked if there is a schematic for the vision the team is aiming for regarding ‘integrated reporting’. AB stated that the team already have some generalisable issues and are starting to codify what the issues are. A high level skeleton of issues will then come out of this and the sessions to be held in December.
  • AT supported the idea of thinking and scaling through common services but cautioned that the current use cases don’t represent the full landscape. He felt the team shouldn’t generalise too soon as they might miss some key issues outside of the current set of use cases. AM assured the committee that work on common services is currently exploratory, and so there is scope for the design of any solution or service to evolve over time as the programme works through new use cases.

Item 3 – Financial Resilience Survey Overview

AB gave an overview of the ‘Financial Resilience Survey’ use case, which has been renamed from ‘RegData’. The use case aims to look at the potential for the current survey to become a regular collection and look at data quality and standards whilst minimising duplication.

Key Discussion Points/Comments:

  • AT asked what the role of the committee should be for deciding on new use cases. AM explained the current set of Bank of England use cases were selected as part of the Data Collection Review, after consultation with industry. He noted the process of deciding future use cases will involve consultation with the Reporting Transformation Committee.
  • Members questioned whether a new regular data collection was in scope of the programme. They had understood the focus of the programme was on changing how we collect data, not what we collect. They doubted whether changing collections would lower the cost of regulatory reporting to industry.
  • RD1 and AM clarified the scope of the programme. RD1 reassured members that this is an opportunity to shape and design the collection and also challenge whether it needs to become a regular collection. She added that regardless of whether the content of the collection changes, there may still need to be a material shift in how collections take place, such as moving from a form-centred collection design strategy to a data-centred one. Implementing these changes may be costly in the short run but lead to longer-term benefits. AM confirmed, from a Bank of England perspective, the scope of the work was to focus on how to collect data. But he noted there are challenges in separating the questions of what data is collected for, and how it is used, from how it is collected. He reminded members that, regardless of the solution, the point of the programme is to deliver effectiveness and efficiency for the authorities and industry, adding that any new collection will have to go through the normal consultation process.
  • GC emphasised the need to keep in mind the objective of the project as a whole. It will take time to reengineer how firms send data and for regulators to define a single set of data points they require. Until then the project should focus on small wins in order to help the team progress towards the overall aim. AM agreed that in order to transform data collection we have to invest early and look at use cases where the value is in enabling future value.
  • RP queried the value in creating a new report for the Financial Resilience survey. He argued it was not clear from the information presented how this activity links back to an agreed problem statement. He emphasised that there was a pressing need to collectively agree the high-level vision and problem statements that we are trying to resolve, noting the first objective in the in 2-year project goals discussed at the inaugural Transformation Committee meeting to create “a detailed shared understanding of the problems faced by all parties involved in the data collection process”. In RPs opinion this activity had not yet happened and needed to be resolved to ensure resources are used on the most valuable activities.

Item 4 – Commercial Real Estate Overview

SH gave an overview of the commercial real estate (CRE) use case and work underway. She said the team is looking at current data collections around CRE to understand the users and identify any current issues or potential overlaps with other collections.

Item 5 – Form DQ Problem Statements

EM presented a summary of the outputs from the Form DQ analysis week. The week consisted of analysis of findings from discovery so far, including interviews with the Bank of England (BoE), Office for National Statistics (ONS) and reporting firms. EM outlined the key issues identified and asked users to comment on which of the ‘how can we’ statements they thought were most important and if the team had missed any.

Key Discussion Points/Comments:

  • AT felt there were no gaps in the current list. He felt from the firm side, the most important areas were in the simplification and standardisation of form mappings.
  • RP agreed that it is important to ensure consistency by breaking regulatory data items into their components. Different firms might calculate data items in different ways so there is a need to keep reports low level rather than aggregating too soon. LM agreed and set expectations that the team will have to focus in a small area to start with in order to scale in future.
  • LF felt that it is important to evaluate the insight that regulators and the ONS require from the data in order to ensure that firms can provide the correct information.

ACT: Delivery team to add a ‘How can we’ statement: ‘How can we better understand the insight that users of the data are trying to derive?’

Item 6 – Risks and Issues

SH discussed the risks and issues. She highlighted resourcing, stakeholder engagement and the CRE use case approach as the most important risks currently.

Item 7 – Principles of Human-Centric Design

AM introduced the concept of human-centric design and the role it plays when developing services for end users. AM asked members to comment on whether they thought human-centric design should be a key principle for the programme.

Key Discussion Points/Comments:

  • AT supported the concept in general, but urged the team to consider that not all pain points can be uncovered by looking purely at the BAU process of the end user. There can often be pain points in implementation that shouldn’t be overlooked. Also, even if the end user at the firm end doesn’t identify any issues, there still may be data quality issues for the regulator. AM confirmed that the team will need to look at the needs of all users, including the regulators, and the service should be designed to meet all of these needs.
  • AT also highlighted the need for all solutions we produce to be scalable.

Item 8 – Postponing the Liquidity Metric Monitoring (LMM) Tool Use Case

AM proposed postponing the LMM use case due to limited resource in the delivery groups. The team believes it would be better to focus the efforts of the group onto the use cases already in progress.

The committee approved the decision to delay the start of the use case.

Item 9 – Vendor Engagement

AB outlined the current process for vendor engagement. The team wants to be open and get the perspective of vendors who have a wide range of experience and may have more specific insight on current issues faced by reporting firms for regulatory data collections.

Key Discussion Points/Comments:

  • LF agreed that there is a lot to be gained from engaging with vendors. However, the team needs to ensure that a vendor who produces a regulatory package isn’t the sole vendor involved as this may lead to a lack of innovation. The team should be engaging with a range of vendors and ensure that the regulators (BoE, PRA and FCA) own the IP of any solution developed.
  • GC felt that the main issue will be around data gathering and this might be an area vendors will struggle to come up with a solution. He felt we should aim to engage with a data provider that could help standardise client-specific data elements that need to be collected.
  • AT stressed that the team shouldn’t be speaking purely to RegTech vendors but should widen the scope depending on the needs of the use case.

ACT: Members to send contact details of any relevant vendors to the secretariat

Item 10 – Communications

AM gave an overview of the communication the team published on 30/09 which outlined the expected resource requirements from industry for the FY 2022/23.

Item 11 – Forward Agenda/AOB

AM presented the dates of the next committee meetings and ran through future agenda items including an update on the Reporting and Data Standards Transformation board and progress of the use cases.

AT requested that future meetings cover the process for deciding the next phase’s use cases and clarifications on the scope of the programme and role of the committee in offering recommendations.


Andy Beale (AB), Financial Conduct Authority (Interim TDC Programme Manager)
Pardeep Bhatti (PB1), Metro Bank
Paul Burleton (PB2), BNY Mellon
Graham Cohen (GC), BNY Mellon
Jacqueline Davies (JD), TSB Bank
Rebecca Ding (RD1), Financial Conduct Authority (Transformation Programme Lead)
Richard Dunne (RD2), RSA Group
Dayo Forster (DF), Bank of England (Product Owner)
Lee Fulmer (LF), UBS
Sharon Howells (SH), NatWest (TDC Project Manager)
Sandy Leggeat (SL), Goldman Sachs
Elizabeth Maloney (EM), JP Morgan (TDC Project Manager)
Robert McBride (RM1), Lloyds Banking Group
Ruaidhri McInerney (RM2), Macquarie Group
Angus Moir (AM, chair), Bank of England (Transformation Programme Lead)
Derek Paine (DP), Mizuho International plc
David Palmer-Lewis (DPL), Principality Building Society
Kamal Patel (KP), Barclays Group
Robert Pengelly (RP), Nationwide Building Society
Charles Resnick (CR), ClearBank
Aaron Shiret (AS), Bank of England (TDC Secretariat / Data Standards)
Tammy Solomon (TS), Investec Bank plc
Robert Thickett (RT), Building Societies Association
Paul Thirtle (PT), NatWest
Andrew Turvey (AT), Belmont Green
Martin Udy (MU), Bank of England (External Engagement Lead)
Richard Walker-Smith (RWS), Bank of America
Rebecca Whitwam (RW), Bank of England (TDC Secretariat)


Mark Hutchison, Scotiabank
Mark Jones, Cambridge & Counties Bank
Daniel Sadler, ABI
Angel Serrano, Santander
Simon Shapiro, HSBC


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G7 Finance Track – Central Bank Governors meeting: Chair’s statement on diversity and inclusion, December 2021

Bank of England Governor Andrew Bailey hosted a virtual meeting of G7 Central Bank Governors earlier this week, which included a discussion on progressing diversity and inclusion in our central banks and the wider financial system. The meeting followed previous discussions among the group on this issue, which commenced under the Canadian Presidency in 2018. In the meeting, G7 Central Bank Governors gave their personal support to work proactively to improve diversity and inclusion within their central banks and financial systems, where possible, recognising both the collective ambition which they share in this area, and the imperative of progress.

G7 Central Banks are united in a shared view that diversity and inclusion are key sources of strength in the workplace, helping central banks make better decisions and policies in the service of their societies. During the meeting, G7 Central Banks agreed to work proactively to broaden the diversity of experiences, backgrounds and perspectives in their workforces, and ensure that inclusion is an integral part of the culture of their central banks. They are taking actions to achieve this goal individually, including through efforts to attract, retain and develop diverse workforces, to engage with a broader set of stakeholders and to make their public communications more relatable, reinforcing their accountability. They are also sharing experiences with each other and seeking opportunities to collectively promote diversity and inclusion in the broader economics and finance community, including through events such as the Conference on Diversity and Inclusion in Economics, Finance, and Central Banking, held last month in Washington DC and organised by the Bank of Canada, Bank of England, Board of Governors of the Federal Reserve System, and European Central Bank. Drawing on their collective experience, G7 Central Banks will seek to expand existing initiatives where possible, while respecting the differences in their national contexts.

To accelerate progress, the group further agreed to continue their engagement on this issue, supported by the network of G7 Central Bank HR/Diversity & Inclusion leads, established in 2018. Complementing this, a representative group of G7 Supervisory Authorities, chaired by Bank of England Deputy Governor and CEO of the Prudential Regulation Authority Sam Woods under the UK Presidency, have met to discuss fostering greater diversity and inclusion across G7 financial sectors. The group agreed that it is important for supervisors to consider issues of diversity and inclusion in the financial sector, and to continue their discussion and engagement on this topic.

Speaking after the meeting, Bank of England Governor Andrew Bailey said:

“As we seek to rebuild from Covid, G7 Central Bank Governors agree on the importance of furthering diversity and inclusion within our central banks and the wider financial system. Our recent discussions have allowed us to share approaches to improving diversity and inclusion. I look forward to progressing our work through the opportunities we have collectively identified, while continuing to learn and share our experiences.”


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Improving depositor outcomes in bank or building society insolvency

The Bank of England’s Policy Statement on its review of its approach to setting a minimum requirement for own funds and eligible liabilities (MREL), published in December 2021, stated that “the Bank considers that recent innovations in technology in the banking system may afford opportunities to mitigate disruptions that may occur in the insolvency of a failing mid-tier firm whose business model is dominated by transactional account banking. These developments include Open Banking and ‘linked accounts’ technology.

The Bank has initiated work to be carried out in consultation with the banking industry, Financial Services Compensation Scheme (FSCS), Financial Conduct Authority, Prudential Regulation Authority and other interested parties with a view to developing alternative processes which may reduce disruption to transactional accounts in the event of an insolvency procedure. Subject to the outcomes of this work, the Bank is considering whether it could significantly raise or remove the transactional accounts threshold”.

Currently, the FSCS aims to effect pay out of eligible deposits within seven days of a bank or building society failing. Payments to individuals in more complex cases will take longer. Even with compensation within FSCS coverage limits being paid within this time, customers may need to open another current account. This may not be straightforward, especially for more vulnerable members of society. Thus, while an FSCS pay-out is underway, depositors may temporarily lose access to their funds at the bank or building society in insolvency.

The impact of this would depend on the depositor profile of the bank or building society in question, in particular the proportion of depositors whose primary source of income is paid into the bank and/or who rely solely on their accounts with the failed provider for day to day banking services, for example standing orders and direct debits, or small businesses making payments to their employees and suppliers.

The Bank, working with other authorities and with the private sector, wants to explore opportunities to minimise the disruption caused by insolvency to those depositors who are protected by the FSCS but are reliant on their accounts with the failed firm for day to day banking and access to money.

As well as the benefits to depositors of these improved outcomes in insolvency, this work could have broader benefits for the UK banking sector. It would make it less likely that (despite having a large number of active current accounts) smaller banks with balance sheets of less than £15 billion to £25 billion would be required to maintain recapitalisation capacity, typically in the form of equity or subordinated debt in addition to minimum capital requirements, that is needed to support a bail-in or partial transfer resolution strategy in order to meet the MREL. This would reduce costs for smaller and growing banks, supporting innovation and competition in the UK banking sector, while reducing risks to UK financial stability should they fail. We note, however, that this work will take some time to complete and so the Bank does not envisage being able to make any consequential changes to resolution strategies and MRELs for individual firms before end-2022 at the very earliest.

We anticipate that industry innovation and support will be a key part of reducing disruption to transactional accounts and improving depositor outcomes in the event of an insolvency procedure. Therefore, at this initial stage, the Bank is interested in hearing from anyone, not limited to the financial sector, who may be able to suggest how best innovative, cost-effective and efficient solutions could be developed and implemented. If you would like to make a suggestion for consideration as part of this work, please contact  As this work develops it will be subject to formal procedures, such as public consultation, as appropriate. 


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The Alternative Liquidity Facility | Bank of England

News release

The Bank of England has today opened the Alternative Liquidity Facility (ALF), which has taken deposits from participating UK-based Islamic banks for the first time.

The ALF was launched in a speech given by Andrew Hauser, Executive Director for Markets, in December 2020. It is a non-interest-based deposit facility, the first of its kind offered by a Western central bank, designed to provide banks that cannot pay or receive interest with a similar ability to place funds at the Bank of England as conventional banks. This is an important step in providing a level playing field, and enabling greater flexibility in meeting regulatory requirements under Basel III prudential rules.

Under the ALF model, participant deposits are backed by a fund of high quality Shari’ah compliant securities known as sukuk. The return from these instruments, net of operating costs, will be paid to depositors in lieu of interest. In the first instance, the fund has purchased sukuk issued by the Islamic Development Bank.

Commenting, Head of Sterling Markets, Rhys Phillips said; “the ALF will help the UK Islamic finance sector to compete with conventional peers while staying true to their founding principles; and will further strengthen the United Kingdom’s role as the leading international financial centre for Islamic finance outside the Muslim world.”


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Minutes of the Post-Trade Task Force meeting – November 2021

Date of meeting: 4 November 2021
Location: This meeting took place via video/audio link


Item 1 – Opening remarks

The Chair welcomed those who had joined the meeting of the Post-Trade Task Force (the “Task Force”) and thanked those who had provided feedback on the draft final report (the “Report”).

Item 2 – Discussion on Task Force report and recommendations

The Chair led a discussion about the extent to which the issues addressed in the Report could be solved by commitments and changes made by the institutions represented on the Task Force alone. It was recognised that a key challenge (and part of the reason these issues remain outstanding notwithstanding earlier attempts to address them) is that, at individual institution level, the costs of addressing these issues are material while the benefits from doing so cannot be realised unless measures are adopted industry wide. As the incentives for smaller users to make such changes are less, the likelihood of securing such industry wide adoption is low, and therefore such changes are typically not deemed a priority for discretionary spending allocation even amongst the largest industry participants. Thus, as recognised in the draft Report, the Task Force’s view is that only with support of some type from regulators is change likely to take place that materially addresses the issues. However, the Task Force acknowledged that the regulatory agenda was typically full and it was incumbent on the industry to take as much action as they could independently, and for the Task Force to explain articulately where regulatory action would contribute to the common good of the market that could not be achieved through independent action.

The Task Force identified a number of reasons why regulators might see these issues as priorities. Whilst some of the issues relate to efficiencies and thus if solved would result in costs savings, the issues discussed by the Non-Economic Data and Uncleared Margin working groups create operational risks which in a stressed situation could create systemic risk. Also, the length of time taken to onboard clients is clearly not in the best interests of clients and could affect the competitiveness of the UK market.

The Chair summarised the three main reasons why the Task Force believed these were matters that should be of concern to regulators. Firstly, solving them could make the UK a more attractive place to do business. Second, the suggested measures would only be beneficial if adopted by the whole market, but the Task Force (or similar) alone cannot drive industry-wide change and regulatory impetus is required to change the cost-benefit analysis for all. Thirdly, the issues outlined, if left unaddressed, could pose or contribute to an important prudential and systemic risk in a time of stress.

The Task Force members agreed that the recommendations are sensible and that they are all things their institutions should implement, but that it would only become a priority to do so when the benefits could be realised, which required market-wide change.

In terms of client onboarding, the Task Force agreed it would be useful to spend time with the regulators with a view to reducing the vagueness around onboarding requirements and implementing LEIs on all transactions in wholesale markets.

On collateral management, the Task Force noted the FCA’s efforts on operational resilience and agreed it could be effective to require publication of statistics, and that this could fit neatly within the existing operational resilience regime. Requiring reporting of failure rates alongside reasons would focus attention to fixing these issues.

Turning to the suggestion on developing a Post-Trade Industry Leadership Group, the Task Force members noted that they and other senior individuals within their institutions agree that these issues are worth dedicating more time to, if there is a reasonable prospect of measures being implemented.

Item 3 – Administrative matters

The Chair requested approval for a final 2021 Linklaters invoice that was slightly higher than the previous 2021 estimate due to additional work performed in relation to report writing and review, one additional Task Force meeting, and continuation of the project beyond the originally anticipated 12 months. There were no objections from the Task Force members and the Task Force instructed Linklaters to proceed to invoice each Task Force member.

Item 4 – Next steps and closing remarks

In terms of next steps, the Chair noted that a meeting would be set up with the Bank of England in the next few weeks. The Task Force would share its suggestions and requests in that meeting and then there would be a period of time for the regulators to consider. Following those conversations, the requests and next steps to be outlined in the report could be finalised.

The Chair noted that the draft report is otherwise close to final and invited any further comments to be sent via email. The aim is to circulate a final report at the end of November with a view to publication at the beginning of December. This could then be followed by engagement with the regulators in early 2022, depending on the appetite for this from the regulators.

The Chair thanked the Task Force members and their institutions for all their efforts, as well as AT for authoring the report. The Chair closed the meeting.

Committee attendees

David Hudson (Chair), JP Morgan
Robert Lamb, Blackrock
Chris Bush, Bank of America
Gerson Riddy, Barclays
Andrew Douglas, DTCC
Gareth Jones, Euroclear
Risa Lederhandler, Goldman Sachs
Marcus Robinson, LCH
Siobhan Clarke, M&G Investments
Philip Glackin, JP Morgan
Sanjay Dhir, JP Morgan
Mike Irwin, XTX Markets


Merav Pepere, Morgan Stanley
Akbar Sheriff, State Street
Jeremy Lewis, Credit Suisse

In attendance

James Tulloch, Bank of England
Michael Kent, Linklaters
Bethan Poole, Linklaters
Anabel Thomson, Re:link
Clair Graystone, Morgan Stanley
Aamanveer Binning, M&G Investments


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Transforming data collection – request for input to the solution design for our use cases


Following work with the Financial Conduct Authority (FCA) and Industry, and as a response to the Future of Finance report, the Bank of England (BoE) carried out a review of Data Collection in 2020. The review aimed to understand what issues industry face in supplying the data, what issues the BoE faced with receiving and using it, and what collectively is needed to do to tackle those issues. At the end of the review, the BoE published ‘Transforming Data Collection from the UK Financial Sector: A Plan for 2021 and beyond’ (the Transformation Plan) on 23 February 2021.

Alongside the publication of the Transformation Plan, the BoE and FCA sent a Dear CEO letter to give an update on progress and plans for 2021, and to ask for engagement from firms. A Town Hall was held in Spring 2021 to communicate and discuss these messages with relevant stakeholders, and explain our plans for a joint transformation programme with industry. This joint transformation programme sets out a vision and approach to delivering improvements in data collection over the next decade.

The vision of the joint transformation programme is that: ‘The Bank of England, Financial Conduct Authority and other users get the data they need to fulfil their mission, at the lowest possible cost to industry.’

In order to realise the vision, the BoE, FCA and financial services industry (including third party suppliers to financial firms) will need to transform how we manage and collect data. In particular, the review identified three key reforms that need to take place:

  • Defining and adopting common data standards that identify and describe data in a consistent way throughout the financial sector. These common standards should be open and accessible for use by all who need them. Their adoption will bring benefits well beyond reporting.
  • Modernising reporting instructions to improve how our reporting instructions are written, interpreted and implemented. There are a range of steps we think this will involve, from setting up better Q&A processes to potentially rewriting our instructions as code.
  • Integrating reporting to move to a more streamlined, efficient approach to data collection. This reform includes making data collection more consistent across domains, sectors and jurisdictions, and designing each step in the data collection process with the end-to-end process in mind.

We don’t think the reforms can be achieved quickly or easily. We are aware of the difficulties we and industry will face moving away from legacy solutions. And many of the changes required will be cultural as well as technical, with sustained investment required to make the range of improvements we have identified.

Joint transformation programme

Central to our plan to deliver the reforms is our joint transformation programme which commenced in July 2021. Alongside BoE and FCA staff, the programme compromises industry participants with a wide range of knowledge and experience, drawn from across the financial sector. Following a nominations process, participants were selected in line with our selection criteria. There are currently around one hundred participants working across the programme from over forty regulated firms.

The joint transformation programme thinks the issues the industry and the Regulators face can be summarised in three key questions:

  • How can we ensure our data collections are worthwhile and valuable exercises for regulators and industry to invest in?
  • How can industry best understand and interpret our reporting instructions so that high quality data is provided?
  • How can we remove legacy data, process and technology siloes and streamline the reporting process?

The joint transformation programme is taking a use case approach in this work to research, design and test solutions to address the issues the regulators and industry face. The three use cases for 2021/22 are:

  • The Quarterly Derivatives Return – a Bank of England return
  • Commercial Real Estate reporting – a Bank of England return
  • The Covid-19 Impact survey focussing upon the Financial Resilience elements – an FCA return

We wish to engage all stakeholders with relevant knowledge and expertise in areas that relate to the Quarterly Derivatives Return and Commercial Real Estate reporting use cases. This request for input is part of our engagement process with third party suppliers to the financial services industry.

The use cases

Quarterly Derivatives Return


The Financial Derivatives return (Form DQ) is a high-level view of the value of the derivatives business done by UK banks. It is submitted quarterly to the Bank of England. The data also feeds into the UK ‘financial account’ – the ONS’ estimate of the UK economy’s balance sheet and financial flows, which are used by economies and businesses to understand changes and risks in country markets and sectors. They also help the ONS to sense check their calculation of financial services output in GDP. The data are defined and prepared in accordance with international rules on the preparation of economics statistics, known as the System of National Accounts (SNA 2008) and the Balance of Payments Manual (BPM6, maintained by the IMF). Form DQ and the instructions for how to complete it are communicated on the Bank website. Please see the appendix for links and further details to the requirements mentioned above.

Key challenges with the Quarterly derivatives return

Whilst the existing return has been operating for a number of years, there are a number of opportunities and drivers for change:

  • Firms are likely to process and reconcile the data in different ways which means that the data is not necessarily comparable
  • Firms have to maintain a range of mapping tables associated with products and counterparties which are expensive to maintain and likely to be implemented in different ways
  • The Bank undertake a range of plausibility checks with firms as quality assurance but these can be unnecessarily time consuming for firms
  • The existing way the requirements are communicated via the Bank’s website require further interpretation and is not user friendly
  • There are proposed new changes to the international statistical standards which will call for further detail of required derivatives data but cannot be delivered through existing data collection
  • There are a wide range of parallel data-related initiatives in the derivatives space which may provide solution opportunities

Commercial Real Estate (CRE) reporting


A report by the Investment Property Forum and Real Estate Finance Group, sub titled “Recommendations for reducing the risk of damage to the financial system from the next commercial real estate market crash” was published in May 2014. This outlined the importance of the role played by commercial real estate (CRE) in the wider economy and in particular its contribution to economic growth and prosperity, as well as its potential to cause or exacerbate financial crises. Among the recommendations was the creation of a comprehensive UK CRE loan database to help the regulator understand the market better, and participants make more informed decisions around their lending. There are a number of existing voluntary collections in the market.

Key challenges with the CRE

  • The existing collections do not capture all participants (eg it excludes non bank entities)
  • The current underwriting collection is adhoc. It requires authorisation to collect the data each year which has implications for both the Bank and firms who are uncertain whether it will happen every year and have to set resource aside to manage the process
  • There are some specific data standards issues which need to be tackled – for example in how valuation data is defined and created
  • There are a number of existing voluntary collections in the market

How can you help?

We are reaching out to suppliers to support our design phase for our use cases in order to find potential solutions to the issues we face. Any potential solutions will need to address elements or all of the ‘How can we’ statements which are outlined in the design brief below. Potential solutions will also need to cover how they could deliver benefit in the short, medium and longer term. The ‘How can we’ statements have been identified as the priority areas to solve to deliver value for stakeholders and have been defined after our discovery phase. We will be holding demo days where interested parties can describe:

  • The solution idea(s)
  • The key hypotheses for change/ benefits
  • Key milestones on a theoretical implementation road-map (covering initial steps, and well as longer term milestones)
  • Key implementation risks

All submissions will be reviewed by the joint transformation programme. Some vendors will be invited to attend one of our demo days to present their proposal to a small panel of representatives from the FCA, BoE and reporting firms involved in the joint transformation programme. We may also follow up separately with other vendors depending on the basis of the proposal.

If you would like to submit a potential solution for consideration, please outline your proposed solution demonstration covering the key areas described above in this template and send to Please use the attached template for your submission. Please note submissions should be no more than two pages. We will then let you know if we intend to include your proposal in this set of demo days.

Please note, this is not part of a procurement process. Any procurement process will be a separate process and may include aspects of information gained from this demo process.

The joint transformation programme will be carrying out a similar process for further use cases. These will be communicated at a later date.

The Design Brief and “How Can We” statements

Quarterly Derivatives Return

We have prioritised two main focus areas. One in an area related to data standards, and one related to reporting instructions. These are the areas we are seeking ideas for solutions for. The characteristics of the solutions are that they need to:

  • Focus on the precise data requirements of this return today and possibly in the future
  • Delivers a range of benefits including more consistent/ trusted data, flexibility, scalability and a positive trade-off between costs and management benefits for firms/Bank over time
  • Deliver end to end impact/ value to stakeholders involved in the production and use of the data, including Firms, the Bank of England, the ONS and international bodies such as the IMF and Bank for International Settlements
  • Be easily understandable for a range of audiences
  • Define critical no regret features/solutions which could deliver value in the short term as well as have longer term impact

We will be assessing the proposed solutions against these characteristics.

The ‘How can we’ statements – Quarterly Derivatives Return use case

Statement One

How can we meet the quarterly financial derivatives market reporting needs of the current and future anticipated international standards (SNA, BoP) requirements in the most consistent, effective and efficient way

Delivery of the DQ report by firms involves calculations and mappings which are costly to deliver, and are reconciled in different ways between businesses. Whilst current reporting meets the needs of the ONS, moving forward proposals for future additions to these reporting standards have been published by IMF that will require extended and more detailed data submissions. For DQ, this is part of a complex derivatives reporting environment which raises challenging questions concerning how counterparties, product, services, currencies, costs and income are understood, defined and recognised. At the same time in the derivatives area there are a wide range of initiatives associated with data standards which could potentially inform the way forward by offering efficiencies. We would like to understand what sorts of solutions could be implementable to deliver benefits for the ONS, Bank and Firms to increase trust in the market and reduce costs for form DQ.

Statement Two

How can we communicate and embed DQ-related reporting requirements in the most effective, consistent and flexible way?

The current BoE website describes the requirements for form DQ (see links in the appendix) but requires considerable interpretation leaving scope for inconsistency, and is not user friendly. We would like to understand how DQ – related reporting requirements could be communicated in a way which minimises ambiguity and makes it easier to deliver high quality consistent data.

The ‘How can we’ statements – Commercial Real Estate (CRE) reporting use case

Statement One

How can the Bank efficiently get the CRE data it needs to proactively monitor and intervene if necessary?

Whilst some progress has been made in creating a voluntary CRE database over the last few years, we are still some distance away from industry committing to and delivering the scope and range of data the Bank needs to perform its role in the market. It is known that some jurisdictions have made good progress in this area, so there are potentially some transferrable ideas and solutions. We would like to explore what ideas the community has to accelerate progress in this area.

Statement Two

How can we communicate and embed (CRE-related) reporting requirements in the most effective, consistent and flexible way between the Bank and firms including expectations, feedback and other useful information for firms

The current approach to communicating expectation and feedback does not facilitate shared understanding. How could this improve?

Key dates

  • Publication of the Request for Input – 30 November
  • Submission of proposed solution sent to – 10 December
  • Response from the joint transformation programme to selected solution providers with time and date of demo by 21 December
  • Presentation at demo day
    • Quarterly Derivatives Return use case – 12/13 January 2022
    • Commercial Real Estate (CRE) database use case – 19/20 January 2022


Quarterly Derivatives Return use case

Bank of England – forms, definitions and validations
Bank of England – Transforming data collection
Form DQ box codes
Form DQ definitions
Future of Finance report
IMF Balance of Payments Manual (BPM6)
IMF FITT Draft Guidance Note, ‘F.4 Financial Derivatives by Type’ (2021)
System of National Accounts 2008 (SNA 2008)

CRE use case

BPF – Commercial Property Forum – London
CRE Underwriting Standards Review Template
The UK Commercial Property Lending Report (Bayes Survey)
Financial Stability Reports | Bank of England Commercial property has featured as a focus in several of the last few financial stability reports
Investment Property Forum and Real Estate Finance Group (Recommendations for reducing the risk of damage to the financial system from the next commercial real estate market crash)
Stress Test Data Framework Manual (
The Federal Reserve – reporting firms for CRE

Transforming Data Collection and the Joint Transformation Programme

Bank of England – Transforming data collection
Transforming data collection from the UK financial sector – the Transformation Plan


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Minutes of the London FXJSC Operations Sub-Committee Meeting – 15 September 2021


Item 1 – Welcome and Apologies

John Blythe (Chair, Goldman Sachs) welcomed members to the FXJSC Operations Sub-committee meeting held via conference call. Mr Blythe welcomed guest presenters Sharon Wallis, James O’Connor, Bhavin Patel, and Nicholas Butt (Bank of England).

Item 2 – Minutes of the 9 June meeting

The minutes of the 9 June 2021 meeting were agreed. There were no matters arising.

Item 3 – Sector Response Framework

Sharon Wallis (Bank of England) presented to members on the Sector Response Framework (SRF), highlighting the importance of co-ordination in enabling the UK Financial Sector to respond to operational disruption to ensure continuity of operations and stable functioning of Retail and Wholesale markets. Ms Wallis explained that the SRF aims to facilitate this response in providing guidelines and capabilities that enable sector groups to respond concurrently or on a modular basis.

The benefits of SRF include: enhancing awareness of sector-wide capabilities; clarifying understanding between strategic and tactical co-ordination as well as decision-making authority; information sharing and operating principles; and providing a framework in which skilled teams across the sector can come together and respond as required. The framework also provides a lexicon to provide consistency and standardisation in relation to how firms describe their incidents externally to support in further harmonisation across industry.

An overview was provided of the different components which make up the SRF, including the core framework, group templates and integration guidelines, and a schematic of the SRF and its associated groups.

Members noted that the documentation is helpful and provides a useful avenue for further integrating firms response plans within the financial sector. Members discussed challenges with balancing co-ordination across several stakeholders and recovering from an incident at the same time.

Item 4 – FXJSC Turnover Survey

James O’Connor (Bank of England) presented the April 2021 FXJSC Turnover Survey results. Relative to October 2020, there had been a rise in FX activity, reaching record highs in April up 16% over the last 6 months and 24% year on year. This rise was driven largely by increases in FX Swaps, which rose by 18% since October 2020, although turnover increased across all other products. Similar increases were seen in the US, Canada, Singapore and Tokyo, although one exception was Australia which saw a decrease in turnover over the last year.

There was an increase in trading of all major currency pairs. Trading in EUR/USD rose 17% from October 2020, to a record high, and both USD/CAD and USD/AUD saw particularly large increases in turnover, with USD/CAD reaching an all-time high, rising 47% since October. Turnover in sterling pairs was also high, if a little lower than the peaks seen in 2019. Turnover also increased across Emerging Market currencies, which was similarly driven by FX Swaps.

Since the previous turnover survey there has been an increase in both the number of trades and the average trade size, rising by 4% and 11.5% respectively since October 2020.

Item 5 – Digital Assets

Nicholas Butt and Bhavin Patel (Bank of England) presented on the Bank of England’s work on Central Bank Digital Currencies (CBDCs). Mr Patel explained that globally there had been an increase in exploration around CBDCs, noting that 86% of central banks are now engaging in some form of CBDC work, and the pandemic had accelerated the move away from cash to more electronic forms of payments.

Mr Patel gave members an overview of opportunities presented by CBDCs including: resilient payments; avoiding the risks of new forms of private money creation; supporting competition and innovation in payments; improving ability and usability of central bank money; addressing concerns of a decline in cash; and as a building block for better cross-border payments. Members discussed the issues around CBDC that may impact the FX market including impacts on accessibility for use by foreign residents or investors, core financial markets and asset prices, cross-border capital flows and exchange rates, FX pricing and margin and implications for settlement and liquidity management.

Mr Butt described how a platform model of CBDC could work, noting in such a model the Bank of England could would offer the core CBDC ledger and payment interface providers (PIPs) would provide the customer interface which would link to the ledger via an Application Programming Interface (API). Feedback on the 2020 CBDC discussion paperfootnote [1] published by the Bank of England was discussed as well as the 2021 discussion paper on new forms of digital money.footnote [2]

In terms of next steps, a Bank-HMT Taskforce is coordinating a cross-authority exploration of UK CBDC, including close contact with relevant industries and experts.

Item 6 – CLS Update

John Hagon (CLS) highlighted that in relation to CLS Convergence, the migration of CLS Settlement to the new platform occurred in June and the new platform has been stable since.  While service continues to be strong, there have been a few external impacts to settlement and pay out recently, for which the underlying root cause has been a preference by clients to wait for technical recovery rather than invoke contingency and then subsequent problems with their execution of contingency remotely.

Eurex is currently not processing any live business through CLS. Mr Hagon highlighted that there had been a recent press release related to efforts on designing and rolling out an alternative PvP service for non-CLS currencies in collaboration with a number of global settlement members.

Item 7 – SWIFT Update

Joe Halberstadt (SWIFT) noted that two FX related change requests have been accepted for the country-vote as part of the SWIFT November 2022 standards release. This is a change to add the South Korean Financial Services Commission to field 22L as a reporting jurisdiction. The other is to add support to the MT 300, 304, 205 & 306 for non-deliverable trades in digital currencies. In view of the impact on the industry of migration of SWIFT payments to ISO20022 starting in November 2022, more substantial change requests were postponed.

Item 8 – FCA Regulatory update

Babatunde Carew (FCA) reminded members that the UK Wholesale Markets review consultation period is due to end of the 24 September. This review is led by HMT and was established to determine how the UK’s approach to regulating secondary markets needs to adapt following the UK withdrawal from the EU and ensure the framework caters for future change and opportunities. The FCA plans to release a statement later this year, and regulatory changes that will be informed by the consultation paper will be implemented as soon as parliamentary time allows and will happen alongside the Future Regulatory Framework Review.

Mr Carew noted that since 30 June additional rules have been implemented in relation to FX forwards and swaps. This was in the form of a joint policy statement by the PRA and FCA relating to margin requirements for non- centrally cleared derivatives.

Mr Carew drew member’s attention to the FCA restarting proactive supervision. With COVID uncertainty receding, and material progress being made to reduce risk from EU withdrawal and LIBOR transition, FCA supervisors have begun to restart high-priority pieces of work outside these areas and the FCA will shortly be restarting the suspended elements of the Delivering Effective Supervision framework.

Item 8 – Education & Outreach

i. Operational Manager’s Working Group (OMWG)

Juna Nashi (Citadel) provided an update on discussions at the recent Operational Manager’s Working Group (OMWG). The two main topics of interest included a return to office strategy and CLS. While many US banks and large financial institutions had been targeting September for return to office, some plans have been put on hold due to an acceleration of Covid cases in the US. In relation to CLS, the working group discussed that there could be more engagement and awareness for the buy side as the value proposition is attractive to firms. There was also discussion focused on payments, reducing settlement risk and an industry push to a more systematic way of managing FX settlement.


Steve Forrest (UBS) provided members with an overview of the topics discussed by the European Central Bank (ECB) Operations Managers Group (OMG) meeting on 23 June. Mr Forrest noted the discussion included: an update from Northern Trust on custodial services; cryptocurrencies, distributed ledger technology and digital currencies; a discussion regarding Covid and back to work strategies; and the benefits of an increase in acceptance of digital signatures.

ii. GFXD Update

Mr Forrest provided an overview of topics discussed by the Global Financial Markets Association (GFMA) Global Foreign Exchange Division (GFXD) meeting in June. These included: a review of the Financial Stability Board (FSB) paper related to challenges with cross border paymentsfootnote [3]; how twenty-four hour settlement might evolve; topics of discussion for 2022; and a new working group looking to cover new technology, people, settlement risk reductions and standing settlement instructions.

Item 9 – Any Other Business

The FXJSC Secretariat thanked members for participating in the Committee’s annual contingency call test.

The FXJSC Secretariat conducted a survey to determine member appetite for a hybrid meeting in November.

Next FXJSC Meeting: 17 November 2021


Adam Jukes – Deutsche Bank
Babatunde Carew – FCA
Boyd Winston – JP Morgan
Claire Forster-Lee – Morgan Stanley
Daniel Horgan – Citigroup
Gail Smith – RBC
Gavin Platman (Deputy Chair) – Insight Investment
James Kaye – HSBC
Joe Halberstadt – SWIFT
John Blythe (Chair) – Goldman Sachs
John Hagon – CLS
Kerry Peacock (Deputy Chair) – MUFG Bank
Sharon Chapman – Barclays
Steve Forrest – UBS
Terri Van Praagh – Northern Trust

FXJSC Secretariat

Alice Hobday – Bank of England
Devin Bennie – Bank of England
Lauren Rana – Bank of England
Jeremy Pitblado (Legal Secretariat) – Bank of England

Guest attendees

Bhavin Patel – Bank of England
James O’Connor – Bank of England
Nicholas Butt – Bank of England
Sharon Wallis – Bank of England


Andrew Rogan – UK Finance
Matt Dukelow – Bank of England
Mike Irwin – XTX Markets


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Minutes of the London FXJSC Main Committee Meeting – 22 September 2021


Item 1 – Welcome and Apologies

Andrew Hauser (Chair, Bank of England) welcomed guest presenter Shirley Barrow (Refinitiv Benchmark Services Ltd). Andrew noted that Nina Moylett (M&G plc) and Rajesh Venkataramani (Goldman Sachs) have joined the Main Committee and announced that Frances Hinden (Shell) had stepped down. He thanked Ms Hinden for her valuable contributions to the FXJSC’s discussions since joining in January 2016.

Item 2 – Minutes of the 14 June meeting

The minutes of the 14 June meeting were agreed, with no comments raised by members.

Item 3 – Market Conditions: FXJSC Turnover Survey Results

James O’Connor (Bank of England) delivered a presentation on the April 2021 FXJSC Turnover Survey Resultsfootnote [1].

Overall, average daily FX turnover had reached $2,985 billion in April; that was another record high, and represented a 16% increase since the October 2020 turnover. Turnover had increased across all FX products, but was again particularly driven by FX swaps, where turnover had risen to $1,575 billion, an increase of 18% relative to October 2020. The rise in turnover had been led by major currency pairs; USD/EUR remained the most commonly traded pair in London with average daily turnover of $914 billion.

Daily average turnover had also increased across Emerging Market currencies, with the exception of the Chinese Renminbi (CNH). Members noted normalisation in interest rates across some eastern European countries – namely the Czech Republic and Hungary – had driven greater trading opportunities and had accounted for some of the increases. By contrast, lower volatility and tighter ranges in USD/CNH were likely contributing factors to the fall in CNH activity.

Members noted that turnover had subsided somewhat since the substantial levels seen in April, which had been broadly driven by continued re-opening from Covid-related restrictions. Low volatility and limited trading opportunities had seen a particularly quiet period in FX markets over the summer.

Item 4 – ESG and FX

Lisa Dukes (Drax) presented on Drax’s recently announced FX derivative contracts with an Environmental Social Governance (ESG) component. The contracts incorporated an ESG element whereby Drax would receive a rebate for reducing its carbon intensity below a pre-set threshold.

Two differing methodologies for incorporating ESG considerations into derivative contacts were outlined: either in single derivative transactions or across whole derivative portfolios. The former was relatively simple, and tied a specific trade/project to ESG targets, but was not extended to wider business or strategy. This was potentially most relevant in situations where a standalone project could clearly be linked to ESG goals, e.g. in transition sectors such as mining. Alternatively, a firm could take a derivative portfolio approach, which covered multiple trades across derivative classes. In such an approach, a firm agreed a common ESG-linked overlay (e.g. through an ISDA amendment/side letter) for multiple transactions, linked to its company-wide strategy for the short, medium or long term. The approach was intended to encourage long term relationships with like-minded ESG focused counterparties, and also created a consistent message across the entire business.

Turning to the key considerations for adopting ESG derivatives, it was noted that the implementation of ESG agreements took a reasonable amount of time and resource, particularly the first time round. The legal documentation was relatively simple, though where the process was new for both parties, it inevitably took some time. It was noted that EU banks had typically been ahead of their UK and US counterparts in terms of their ESG service offerings, though the gap seemed to be narrowing as ESG-related considerations became more mainstream.

The introduction of ESG-linked FX derivatives to Drax’s business had tied sustainability metrics into day to day derivative activity, and built on previous work tying sustainability metrics to other treasury operations (e.g. term loans, revolving credit facilities and working capital). Drax noted that the banking sector had reacted very positively to the greater focus given to ESG considerations, and most were working to understand and adopt the initiative.

Members discussed the demand they had seen for ESG related agreements in their different businesses. ESG considerations had perhaps been somewhat later to arrive in FX than in some other asset classes, and the linkages perhaps needed somewhat greater up-front motivation. General market transparency and market promotion around positive ESG efforts was however promoting greater conversation on ESG in the FX market. Members also discussed the mechanics underpinning ESG-linked derivatives, including: responsibilities for monitoring when ESG thresholds were triggered; how the rebate was funded; and how the drive for ESG incorporated broader client outcomes.

Members highlighted the recently published GFXD paper on ESG and FX,footnote [2] which explored a range of challenges and opportunities, particularly drawing out how the FX Global Code could support a firm’s Governance considerations (the ‘G’ in ‘ESG’).

Item 5 – FX Benchmarks

Shirley Barrow (Refinitiv Benchmark Services Ltd) presented on Refinitiv’s latest analysis regarding the WMR 4pm benchmark. Data on trade frequency, price volatility, and price movement around the 4pm window were presented and the major developments to WMR methodology and benchmark services, regulation and user engagement between 2015-21 were also set out.

Ms Barrow noted that, looking forward, WMR had a range of focus areas. These included: investment and technology transformation; engagement with clients to identify and implement enhancements for WMR spot, forward and NDF measures; and continued regulatory compliance.

Members discussed the use of the 4pm fix. They reflected on the volatility seen in March 2020 and discussed the impact of portfolio rebalancing and subsequent large moves around the fixing window. It was noted that use of the fix appeared to have increased among passive managers, whilst active managers have seen decreasing demand from end-clients. Passive management usage was inherently linked to assets under management, so as that segment of the market grew, WMR usage had also been growing.

The Chair noted the importance of efforts, both by WMR and by market participants to continue to broaden and deepen user engagement. WMR noted it had an ongoing outreach strategy aimed at raising awareness and knowledge around the fix. Members underscored the importance of engaging with the passive management community in particular, given their greater use of the fix.

Item 6 – GFXC Discussion

Following the conclusion of the three-year review of the FX Global Code (Code), the FXJSC Chair proposed submitting a formal request to the FCA, on behalf of the FXJSC, for it to consider re-recognising the updated Code text as an ‘FCA recognised industry code’ in the UK.footnote [3] Members agreed to submitting a request.

The Committee discussed what an appropriate timeframe for members to refresh their Statement of Commitment to the Code would be. It was agreed that all relevant FXJSC members should target updating their Statements by the end of July 2022 at the latest. This would be in line with the Global FX Committee’s (GFXC) expectations and the anticipated timelines set by other local FX Committees for their memberships. Those FXJSC members that required additional information were asked to contact the Secretariat in the first instance.

Grigoria Christodoulou (Bank of England) noted that, following the publication of liquidity provider (LP) and FX e-trading platform cover sheet templates in August, the GFXC was looking to assist an early group of LPs and platforms in populating and publishing their disclosures cover sheets before the end of this year. The ability of FX market participants to make informed decisions was important to the overall integrity and effective functioning of the FX market, and clear, easily accessible disclosures were therefore a critical aspect to the success of the Code. It was requested that relevant FXJSC members consider being a part of that early group, and that those interested should contact the Secretariat.

Hugo Gordon (The Investment Association) provided an update on the Investment Association’s work on standardising reject codes, with the aim of bringing about greater standardisation by Q3 2021footnote [4].

Item 6 – Legal Sub Committee Update

The Legal Sub-committee had met on 14 September 2021. Agenda items included: an overview from the Bank of England on the legal issues arising from the review of the FX Global Code; Leslie Jacobs (EMTA) introduced the Emerging Markets Traders Association and their upcoming work; and the Bank of England provided an overview of the recent update to the UK Money Markets Code.

Item 7 – Operations Sub Committee Update

The Operations Sub-committee had met on 15 September 2021. Agenda items included: an overview of the Sector Response Framework from the Bank of England; and an update on Digital Assets also from the Bank of England.

Item 8 – Update from the FCA

The FCA noted the upcoming deadline for HMT’s Wholesale Markets Review and identified some areas which might be relevant for the FX market. The FCA also stated that it was restarting its proactive supervision work and that the transitional period for all third country benchmarks in the UK Benchmark Regulation had been extended until end-2025.

Item 9 – Update from the FMSB

The FMSB highlighted two recent and key publications. Firstly, the FMSB large trades paperfootnote [5], published in May 2021, sets out the expected behaviours for the execution of Large Trades by participants in FICC markets. Secondly, the Hybrid Workingfootnote [6] paper examines the remote working risks in FICCC markets.

Item 10 – Any Other Business

Next FXJSC Meeting: 23 November 2021


Alan Barnes – Financial Conduct Authority
Andrew Hauser (Chair) – Bank of England
David Clark – Refinitiv Benchmark Services Ltd
Giles Page – Citigroup
James Kemp – FICC Markets Standards Board
John Blythe (Chair, Operations Sub-committee) – Goldman Sachs
Kevin Kimmel – Citadel Securities
Lisa Dukes – Drax
Marc Bayle de Jesse – CLS
Neehal Shah – BNP Paribas
Neill Penney – Refinitiv Benchmark Services Ltd
Nina Moylett – M&G plc
Rajesh Venkataramani – Goldman Sachs
Richard Bibbey – HSBC
Richard Purssell – Insight Investment
Robbie Boukhoufane – Schroders
Rohan Churm – Bank of England
Russell Lascala – Deutsche Bank
Sarah Boyce – Association of Corporate Treasurers
Sharon Blackman (Chair, Legal Sub-committee) – Citigroup
Simon Manwaring – Natwest Markets
Sophie Rutherford – State Street
Stephen Jefferies – JP Morgan
Wang Yan – Bank of China
Zar Amrolia – XTX Markets

FXJSC Secretariat

Alice Hobday – Bank of England
Ed Kent – Bank of England
Grigoria Christodoulou – Bank of England
James O’Connor – Bank of England
Jonathan Grant (Legal Secretariat) – Bank of England
Lauren Rana – Bank of England

Guest attendees

Hugo Gordon– The Investment Association
Shirley Barrow – Refinitiv Benchmark Services Ltd


Galina Dimitrova – The Investment Association


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