6th March 2012

BBA and FOA joint response to FSA proposed guidance on transaction reporting strategy trades

As FSA knows, our members recognise the importance of an effective reporting regime which supports the FSA in meeting its statutory objectives, in particular the prevention / detection of financial crime. We are keen to continue to work closely with FSA in the pursuance of this objective, and both the BBA and FOA therefore welcome the opportunity to respond to the FSA’s guidance consultation on transaction reporting strategy trades (the consultation).

We are keen to continue to work closely with FSA in the pursuance of this objective

While members are willing, as always, to assist FSA meet its objectives, the overarching concern arising from the consultation is that the proposed guidance will require additional technology change and/or business process change – which when applied across the industry are considered disproportionate to the likely benefit to be yielded by FSA. We consider that FSA should view this guidance in the context of relatively low volume in stock contingent trades, and the very low likelihood of market abuse occurring where such strategies are used.

Please read our full response below.