FXJSC Combined Operations and Legal Sub-Committee Meeting

Minutes

Minute 1: Welcome and apologies

Chairs James Kaye (FXJSC Operations Sub-Committee) and Sharon Blackman (FXJSC Legal Sub-Committee) opened the meeting and welcomed online and in person attendees.

Minute 2: Minutes of 17 September Legal Sub-Committee, 18 September 2025 Operations Sub-Committee

The minutes from both meetings received formal approval from the respective members of the FXJSC Operations and Legal Sub-Committees.

Minute 3: International Swaps and Derivatives Association (ISDA) Definitions and Changes with Emerging Markets Traders Association (EMTA) - Katherine Tew Darras, Ann Battle, Michelangelo de Marzio, Jonathan Martin

• Market Survey & Update Process: Ms Battle explained the background to the proposed changes to the ISDA FX Definitions, including the 2023 survey that informed the updates.
• Timeline: Updated definitions to be published early March 2026; go-live in November 2027 aligned with Swift release. Swift will discontinue 1998 FX Definitions post-implementation; clearing houses expected to adopt new definitions.
• Key Changes:
  • Digitised definitions in a format that can be updated by publishing new versions from time to time.
  • Integration of ISDA and EMTA definitions.
  • Draft for feedback (fatal flaw) would be circulated 10 December 2025.
  • Major updates include deliverable disruption events and fallbacks (3 core events + 1 optional, plus APAC-specific events).
  • Calculation agent standard from 2021 rates definitions (an update to the standard in the 1998 FX definitions); changes to automatic exercise and novation provisions.
  • “Unexpected holidays” now termed calendar adjustment events; optional with field in Swift if parties agree to use.
• Matrices: Structural simplifications; EM Matrix consolidates EMTA template terms; Developed Market Currency and Settlement Rate Option matrices for currency pairs and settlement rate options.
• Intention is that firms will not have to rely on Master confirmations with counterparties because provisions are in the Main Book and Matrices.
• Implementation: Steering committee in place; 2-year market implementation window; collaboration with Swift critical; guide and extensive market outreach exercise to accompany definitions.
• Education: Materials to be published late 2026; firms will need to tailor industry materials to their individual counterparties.

Minute 4: Feedback from September Main Committee Meeting - James Kaye (OSC Chair)

The Chair provided an overview of the September 2025 Main Committee meeting, noting a discussion on FX market developments and structural themes. The discussion included an update on the April 2025 FXJSC Turnover Survey, which showed record daily average FX turnover driven largely by spot and options activity. Members also discussed the use of Artificial Intelligence (AI) in FX markets and received an update on the work of the Global Foreign Exchange Committee, including FX settlement risk and the implications on the FX market from the UK, EU, and Swiss transition to T+1 securities settlement.

Minute 5: Swift update - Dean Chard (Swift)

It was noted that Dean Chard would replace Joe Halberstadt as a member of the Operations Sub-Committee.

Migration to ISO20022 completed in November 2025; 80–90% pre-migrated. No issues detected; focus now on Cat 3 message updates for Nov 2027 ISDA changes.

Minute 6: CLS update - Andrew Cooper (CLS)

• Average volumes up to USD8.5 trillion daily (from USD8 trillion).
• Annual market wide disaster recovery test was successful (76 members participated).
• CLSNet expansion paused; focus on USD/CNH Payment-versus-Payment (PvP) solution.
• Efficiency improvements: reducing pay-in grids from five to three.
• Actively running AI use cases in sandbox for efficiency testing.

Minute 7: Update on Committee communications around resilience issues - Eleanor Garrett (Bank of England)

Eleanor Garrett explained that various events in 2022 had highlighted the need for a defined process when convening the FXJSC Operations Sub-Committee during potential or realised resilience issues. Accordingly, a working group was formed, and a communications framework was developed to provide clarity on what OSC members should do in this type of scenario. This framework was shared with Committee members for final comments, of which none were received.

Test of notification system was planned before year-end.

Minute 8: GFXC update - Natalie Lovell (Bank of England)

• It was noted that a virtual GFXC meeting was due to take place on 5-6 December 2025. Agenda items included the impact of the move to T+1 securities settlement on the FX market, a panel on stablecoins, an update from ISDA, and IOSCO’s pre-hedging report.
• Ms Lovell also provided an update on the BIS Triennial and GFXC FX Settlement Risk Surveys.

Minute 9: FCA Update - Oliver McCausland (FCA)

• The final IOSCO pre-hedging report was published in November 2025. The recommendations build on existing market standards, like the FX Global Code.
• The FCA had published a consultation on improving the UK transaction reporting regime. This includes a proposal to remove FX derivatives from the scope of transaction reporting requirements. FX derivatives would continue to be reported for UK EMIR derivative reporting. The consultation was open until 20 February 2026.

Minute 10: GFXD update – Rebecca Fishwick (Barclays) & Claire Forster-Lee (Morgan Stanley)

• Bulgaria adopting euro Jan 2026.
• 2026 agenda: manual touchpoints, end-of-day liquidity, settlement risk; aim for greater buy-side and central bank engagement.

Minute 11: AOB

Consideration of periodic joint meetings going forward.

Attendees

Operations Sub-Committee

James Kaye (Chair, FXJSC Operations Sub-Committee) – HSBC

Aaron Mills (Deputy Chair) - Citadel

Andrew Cooper - CLS

Anna Chadderton - Goldman Sachs

Claire Forster-Lee - Morgan Stanley

Dean Chard - Swift

Gail Smith (Deputy Chair, FXJSC Operations Sub-Committee) - Royal Bank of Canada

Gary Cunningham - Insight Investment

James Andrews - JP Morgan

Kerry Peacock (Deputy Chair, FXJSC Operations Sub-Committee) - MUFG Bank

Loic Moreau - LCH

Nimit Jobanputra - Deutsche Bank

Rebecca Fishwick - Barclays

Sally Pearson – CLS

Natalie Lovell – Bank of England

Legal Sub-Committee

Sharon Blackman (Chair, FXJSC Legal Sub-Committee) – Citigroup

David Harris – Financial Conduct Authority

Joanne Napleton - London Stock Exchange Group

Rakesh Shah – Standard Chartered

Rowland Stacey – Goldman Sachs

Simon Goldsworthy – Deutsche Bank

FXJSC Legal Sub-Committee Secretariat

Sakshi Gupta – Bank of England

Matthew Hartley – Bank of England

FXJSC Operations Sub-Committee Secretariat

Eleanor Garrett – Bank of England

Guest attendees

Jonathan Martin - ISDA

Michelangelo de Marzio - ISDA

Ann Battle - ISDA

Katherine Tew Darras – ISDA

Apologies

Baljit Saini – NatWest

Daniel Hoye - NatWest Markets

Fiona O’Riordan - Citi

Gaynor Wood – CLS

Harkamal Singh Atwal – HSBC

James Hull - MillTech FX

Jermaine Nooks - Investment Association

Krisha Somaiya – UBS

Mayank Patel – Bank of America

Nikki Woodley - Northern Trust

Nimisha Kanabar - Morgan Stanley

Sunil Samani - XTX Markets

Tamsin Rolls – JP Morgan Chase