There was a decent chance that authorities could conclude that a substantial regulatory response was necessary to generate the desired improvement in market structure and conduct. But the Code provided the opportunity for the FX market to address the lack of trust and market dysfunction. The Code was developed through a public sector–private sector partnership.
It was a joint effort of central banks and market participants drawn from all parts of the markets: from the buy side, including corporates and asset managers, and the sell side, along with trading platforms, ECNs and non-bank participants.