The Global Foreign Exchange Committee has an issued a report on the FX Global Code at its one-year mark. Also, here is the updated Code (taking into account changes to last look). I have previously noted, in an op-ed for Pensions & Investments, that “Investment managers that are fiduciaries to plans might want to embrace the code and advertise that fact to their plan clients. If there is skepticism of FX as a transparent market, an investment manager could seek to allay these concerns by explaining the code to its plan clients and how the code aims to make the operation of the market less opaque.”
George Michael Gerstein advises financial institutions on the fiduciary and prohibited transaction provisions of ERISA. As co-chair of the fiduciary governance group, he assists clients with tracking, and understanding, the numerous fiduciary developments at the federal and state levels, including the rules and regulations of governmental plans. He also advises clients with respect to the fiduciary duty implications of ESG investing.