Statement by Acting Chairman Caroline D. Pham on IOSCO Pre-Hedging Report

As Acting Chairman of the CFTC, I welcome IOSCO's final report on pre-hedging. Pre-hedging is a well-established risk management practice, underpinned by extensive industry guidance and expertise. I am proud that the CFTC played an active role in IOSCO's efforts, contributing to the review of existing codes and practices, the survey of members and industry participants, the formal consultation process, and the stakeholder roundtables.

IOSCO's final report rightly acknowledges that individual member jurisdictions already have rules in place to address pre-hedging, complemented by industry codes and standards such as the FX Global Code, the Global Precious Metals Code, and the Financial Markets Standards Board (FMSB) Standard for execution of Large Trades in FICC markets. Importantly, IOSCO has made clear that its recommendations are designed to support existing rules and regulations, recognizing that many jurisdictional frameworks are already achieving the intended outcomes. IOSCO has also made clear that its recommendations, which apply across asset classes, align with these industry codes and standards. I believe this alignment is critical to avoid disruption of markets that are essential to the real economy, mitigate systemic risk and promote financial stability.

The publication of IOSCO's final report serves to reinforce the standards the CFTC sets for entities within our jurisdiction. For the avoidance of doubt, the views expressed in the IOSCO report reflect the CFTC's position on pre-hedging. In light of this, I do not anticipate the need for further CFTC rulemaking or guidance to address IOSCO's recommendations.