Observations on ‘flying’ and ‘printing’
30 January 2024
Level of significance of change
Flying and printing is a term used in financial markets to describe misleading practices where firms manipulate bids, offers, or executed trades to give a false impression of liquidity on price. Clients or other market participants may take investment decisions based on this false or misleading information.
Despite the publication of Market Watch 57, there are still instances of possible flying and printing in several markets.
Further, there were cases of management’s failure to control such behaviours including failing to:
- recognize the risks of flying and printing
- implement appropriate surveillance
- submit suspicious transaction and order reports or market observations
Firms also took a long time to investigate potential misconduct.
How does this change my reporting?
There is no impact on trade and transaction reporting.
What do I need to do?
Investment firms should implement internal procedures and controls in order to mitigate the risks of misleading the market by their staff. Such steps include:
- ensuring compliance procedure manuals expressly prohibit flying and printing
- obtain annual attestations from staff that they are not engaging in this conduct
- Training of staff on the prohibition of flying and printing and provide them with detailed explanations of the consequences.
- Take all reasonable steps to ensure that the procedures for the reporting and identification of such behaviour are sufficient. Such behaviours should be considered in risk assessments.
- Ensure that disciplinary procedures offer clear and consistent processes for dealing with misconduct.