A Hard Look at Last Look in Foreign Exchange


The debate over ‘last look’ in foreign exchange trading has resurfaced in 2016 as regulators continue to eye the practice and investors worry about slippage and potential market abuse.



The debate over ‘last look’ in foreign exchange trading has resurfaced in 2016 as regulators continue to eye the practice and investors worry about slippage and potential market abuse.

Regulators are said to be scrutinizing FX dealing platforms that contain last look, a controversial practice that enables market makers to delay or reject trades from customers after they’ve agreed to a quoted price.

In January, the Foreign Exchange Professionals Association (FXPA), held a webinar on examining the implications of last look for the FX markets.

Attorneys with Steptoe & Johnson on the ‘last look’ webinar, advised market makers to be more transparent about how their last look systems operate.

“Regulators take a very dim view of institutional practices that emphasize a lack of transparency and that encourage employees to give either misdirection or less than complete information to counterparties when direct questions are asked,” said Mike Miller, litigation partner at Steptoe & Johnson, who spoke during the webinar.

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