Warning notice statement 14/1

The Financial Conduct Authority (the FCA) gave an individual a warning notice on 28
November 2013 proposing to take action in respect of the conduct summarised in this
statement.

IMPORTANT: a warning notice is not the final decision of the FCA. The individual
has the right to make representations to the Regulatory Decisions Committee (RDC)
which, in the light of those representations, will decide on the appropriate action and
whether to issue a decision notice. The RDC is a Committee of the FCA board which
decides whether the FCA should give certain statutory notices described as within its
scope by the FCA’s Handbook.

If a decision notice is issued, the individual has the right to refer the matter to the
Upper Tribunal which would reach an independent decision on the appropriate action
for the FCA to take, if any.

If either the RDC or the Upper Tribunal decide that no further action should be taken,
the FCA will publish a notice of discontinuance provided it has the individual’s consent.

The following is a summary of the reasons why the FCA gave the individual a warning
notice:

• The FCA considers that, over a period of more than two years the individual, who was a
submitter at a bank, was knowingly concerned in the contravention of Principle 5 by the
bank for significant failings in relation to an interest rate benchmark.

• In particular, the FCA considers that the individual:

o Made interest rate benchmark submissions which took into account requests made by
traders to benefit their positions;

o Colluded with an interdealer broker acting on behalf of a trader from another bank, by
making interest rate benchmark submissions which took into account a request made
by that broker;

o Colluded directly with traders at another panel bank, both by making interest rate
benchmark submissions which took into account requests made by them, and by
making requests to that other panel bank on behalf of traders at his bank, in an attempt
to influence their interest rate benchmark submissions; and


o Took into account the interest rate derivative positions on the trading book for which
the individual was responsible when making interest rate benchmark submissions.