A $382.4M Precedent for a Market With No Best-Ex Law

FXPA's June 2026 guidance recasts FX spread grids as indicative, non-binding references. FM Intelligence reads the redefinition as a best-execution and conduct-risk question, with liquidity providers, trading venues, the data-rich buy side, and conduct regulators each reading the same document as a win.

The Foreign Exchange Professionals Association published guidance on June 29, 2026 defining FX spread grids as indicative, non-binding reference tools, not firm quotes or contractual benchmarks. Spot FX sits outside MiFID II best-execution rules, so a published grid is a voluntary representation, not a regulated price. Dealers internalize about 80% of spot orders, and the realized spread on a given fill can reach a multiple of the grid under stress, by FM Intelligence estimates. The same document is read five ways, with liquidity providers, trading venues, the data-rich buy side, and conduct regulators each gaining from it. The 2016 State Street case, settled for $382.4 million over markups paired with best-execution assurances, frames the unresolved risk.