Inter-professionals Code (IPC) FSA CP47 - ACT Response

Mr Ted Morris
Markets and Exchanges Division
The Financial Services Authority

26 July 2000

Dear Mr Morris

CP47 - The Inter-Professionals Code (IPC)

Thank you for giving us the opportunity to comment on the draft IPC.

At present, most corporate treasuries dealing in the wholesale markets operate in accordance with the London Code of Conduct which is endorsed by the Association as its guide to best practice in these markets. The Association expects to endorse NIPS and IPC as guides to best practice in the wholesale markets for non-investment and investment products respectively. We have reviewed CP47 both to assess what protections are available to corporates operating as market counterparties in the wholesale markets (as opposed to operating as intermediate customers) and also to decide whether the Association should recommend the IPC to its members as a guide to their own behaviour.