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TMA Treasury Markets Certificate study materials
TMA Treasury Markets Certificate study resources

TMA Treasury Markets Certificate: Code of Conduct and Practice of TMA

TMA Treasury Markets Certificate · Work through your exam, one topic at a time.

All guide sections

Code of Conduct and Practice of TMA

Code of Conduct and Practice of TMA tests market-conduct standards for treasury professionals in Hong Kong: integrity, fair dealing, confidentiality, conflicts of interest, order handling, recording and escalation. The exam wants you to identify conduct breaches in realistic desk situations, not recite slogans.

Core rules and concepts

  • Act with integrity, skill, care and diligence; observe proper market conduct; comply with applicable law and TMA rules.
  • Do not misuse confidential information or inside information. Client orders, large flows and non-public positioning are confidential.
  • Manage conflicts of interest: disclose capacity (principal versus agent), avoid front-running, and separate personal account dealing from client business.
  • Handle orders fairly: obtain clear instructions, execute promptly and accurately, allocate fairly, and keep contemporaneous records.
  • Benchmark submissions must be genuine, transaction-based where required, and not designed to move the fix.
  • Escalate suspected misconduct; do not use market practice as a defence for behaviour that is misleading or abusive.

Worked example

A dealer receives a client order to buy USD 50 million USD/HKD and, before executing, buys USD 5 million for the desk. The client order is confidential and material; the desk trade is front-running. The correct sequence is to execute the client order according to instructions, record the order and execution, and only then manage the desk's own risk subject to policy. If the dealer also had a personal account, that trade would need pre-clearance and should not precede the client order. The breach is not cured by later disclosing it; the exam looks for the control failure and the correct escalation.

Traps

Assuming the code applies only to traders; treating disclosure as a substitute for avoiding the conflict; failing to record oral instructions; using a benchmark submission to protect a position; confusing a client order with market colour; ignoring personal account dealing rules.