PUBLIC COMMENT PERIOD – APAC Client Facilitation Proposal



The Global Technical Committee has reviewed and preliminarily approved the APAC Client Facilitation Proposal submitted by the AP Exchanges and Regulatory & Technical Subcommittees. The purpose of this document is to address requirements identified by Hong Kong SFC (Securities and Futures Commission) regarding client facilitation activities.

The document now enters a public comment period in which public review and feedback is encouraged. Once the public comment period closes, the Global Technical Governance Board will meet to review public comments before final approval.

Please post feedback, comments, and questions as replies to this discussion thread.
A link to the proposal can be found at:

The public comment period ends on April 17, 2019.


Posted on behalf of Sourabh, Rathi from BAML:

On behalf of BAML, we welcome the APAC Client Facilitation Proposal submitted by the committee. We are broadly supportive of adding new value in existing FIX tag ExecInst (18) for buy side to explicitly provide the facilitation consent on FIX ticket. As stated in the proposal, we agree that using an existing FIX tag that supports multiple character value is simplified approach to implement consent for both buy side vendors and sell side.

After going through the proposal, we would like to submit our feedback and questions as below:

  1.   Allow Facilitation

Is the expectation that this tag/value pair is used to initiate a facil request or confirm an agreement? If it is to confirm the agreement, the value ‘Allow Facilitation’ can be misinterpreted as it doesn’t sufficiently represent the agreement. Ideally, facilitation is marked to indicate a handshake as opposed to a one-sided value published on new order or amend.

  1.   Consultation and explicit agreement with SFC on implementation

Can you confirm that the proposed solution has been already reviewed by SFC and given in principle confirmation for industry to implement tag 18 instruction as explicit client consent? Are there any further guidance on the level of details to be additionally captured in consent over and above the FIX tag instruction?

  1.   Tag 29 (Last capacity)

We suggest that proposal should state explicitly that there is no change to the tag 29 (last capacity) on facilitation trades to the client. This will continue to follow the industry practice (for APAC at least) of sending value = “3” i.e. cross as principal, when trade is facilitated.

  1.   Solution Market scope

We recommend that proposal of sending facilitation instruction should not be limited/confined to HK market; however, extended as general practice for other markets. Given most of the sell side firms staff are based in Hong Kong, guidance would be in general applicable for APAC markets traded out of HK.


Thanks Sourabh for your comments. To provide more feedback to your points 1 to 4, (and as discussed over the phone)…

  1. This FIX proposal does not replace any established systems that firms have in place to comply with the SFC rules, but will offer an alternative/complimentary system using FIX, that firms can deploy as they need.

  2. A cross industry group including reps from FIX, ASIFMA and ATF met with the SFC to explain this proposal and while they are not able to give explicit approval (as a regulator), the SFC response was supportive, as this proposal could offer the industry an efficient solution, that also complies with SFC rules. In due course, we will be going back to the SFC to update them on this initiative.

  3. That’s a great point. We can add your suggestion to a ‘Recommended Practices Doc’ that can be circulated to industry participants, e.g. “Voluntary adoption of this proposal in jurisdictions outside Hong Kong - in the interest of standardizing workflows and implementing best practice across the Asia Pacific region, firms could consider adopting the proposed workflow in jurisdictions that do not explicitly require client consent for the use of facilitation services.”

  4. Agreed. We can make this point in the circulated Recommended Practices doc, e.g. “LastCapacity(tag 29) values are NOT affected - firms are reminded that the provision of client consent for facilitation services does not change their LastCapacity reporting requirements and the associated standard values commonly accepted in Asia Pacific markets.”