Global Trustee and Fiduciary Services Bite-Sized Issue 1 2025

17 QUICK LINKS AIFMD CRYPTOASSETS EMIR FINTECH MIFID II/MIFIR MMF NBFI OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG ASIA IRELAND LUXEMBOURG NETHERLANDS NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 1 | 2025 NORTH AMERICA SEC Adopts Rule Amendments to the Broker-Dealer Customer Protection Rule On 20 December 2024, the Securities and Exchange Commission (SEC) adopted amendments to Rule 15c3-3 (the customer protection rule) to require certain broker-dealers to increase the frequency with which they perform computations of the net cash they owe to customers and other broker-dealers (known as PAB account holders) fromweekly to daily. The SEC also adopted amendments to Rule 15c3-3 and Rule 15c3-1 (the broker-dealer net capital rule) to permit certain broker-dealers that perform a daily customer reserve computation to decrease the required 3 percent “buffer” in the customer reserve bank account by reducing the customer-related receivables, or “aggregate debit items,” charge from 3 percent to 2 percent in the computation. The amendments will require broker-dealers with average total credits (the amount of cash they owe customers and PAB account holders) equal to or greater than USD500 million to make the computations necessary to determine the amounts required to be deposited in the customer and PAB reserve bank accounts daily, as of the close of the previous business day. The amendments will also more quickly apply the protective measures of the Rule 15c3-3 reserve requirements to cash of customers and PAB account holders that is newly deposited into the broker-dealer. The amendments also recognize that the enhancements to the customer protection measures of Rule 15c3-3 through a daily reserve computation warrant a corresponding reduction of the 3 percent “buffer” that certain broker-dealers must include as part of their customer reserve computation to 2 percent. The amendments will become effective 60 days after the date of publication of the adopting release in the Federal Register. Broker-dealers that exceed the USD500 million threshold using each of the 12 filed month-end FOCUS Reports from 31 July 2024, through 30 June 2025, must perform the customer and PAB reserve computations daily beginning no later than 31 December 2025 (i.e., six months after 30 June 2025). When the amendments are effective, a carrying broker-dealer may voluntarily perform a daily customer reserve computation and apply the 2 percent aggregate debit items reduction, provided it notifies its designated examining authority in writing at least 30 calendar days prior. Link to Rule Details here Link to Fact Sheet here Financial Stability Oversight Council Releases 2024 Annual Report On 6 December 2024, the Financial Stability Oversight Council (Council) unanimously approved its 2024 annual report. The annual report reviews developments in financial markets, identifies vulnerabilities and emerging threats to U.S. financial stability, and makes recommendations to mitigate those vulnerabilities and threats. The report also details the activities of the Council and summarizes significant regulatory developments. The report was developed collaboratively by Council members and their agencies and staffs. Overall, the Council finds that the U.S. financial system remains resilient, though vulnerabilities warrant ongoing vigilance. The Council’s recommendations in the annual report include the following: • Cybersecurity : Significant incidents at major financial institutions have the potential to disrupt critical operations and services more broadly. Financial institutions and systems are highly interconnected, so it is important for all financial sector participants to stay updated on cybersecurity developments within the financial sector and work to reduce cybersecurity risk. The Council supports ongoing partnerships between state and federal agencies and private firms and recommends continued information sharing related to cyber risk and additional work to assess and mitigate cyber-related financial stability risks. The Council also supports the G7 Cyber Expert Group’s international efforts to help financial institutions better understand cybersecurity risks and improve the resilience of the financial system to cyber incidents through preparedness, a consensus understanding of the threat landscape, and a shared approach to mitigating risk.