Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

11 QUICK LINKS FINTECH MIFID II/MIFIR OPEN FINANCE SUSTAINABLE FINANCE/ESG T+1 ASIA AUSTRALIA EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 10 | 2025 Other major observations from the survey included: • Structured products remained the top product type sold by the respondent firms, accounting for 42% (HKD 2,567 billion) of the total transaction amount in 2024. CIS and debt securities rounded out the top three spots, making up 37% (HKD 2,244 billion) and 15% (HKD 941 billion) respectively. • Equity-linked products made up 67% of all structured products sold in 2024, up from 61% in 2023. The major underlying equities of the top five products reported by the large firms were from the technology (42%), automotive (23%) and internet (22%) sectors. • Online sales accounted for 17% (2023: 12%) of the aggregate transaction amount reported by all respondent firms. The number of respondent firms that distributed investment products online continued to grow in 2024, increasing 13% to 104. CIS remained the top product type sold through online platforms, making up 77% of the total online sales, followed by debt securities at 21%. Link to Survey here Revised Guidelines on Licensing and Conduct of Business for Fund Management Companies On 3 September 2025, MAS published updated guidelines which set out the eligibility criteria and application procedures for licensed fund management companies (LFMCs) and venture capital fund managers (VCFMs). MAS also set out the ongoing business conduct requirements for LFMCs and VCFMs, including requirements relating to custody, valuation and reporting, conflicts of interest mitigation, disclosure and submission of periodic returns. The revised guidelines contain updated definitions, additional clarification through footnotes, and an extra criterion regarding investments in non-capital market products for fund management companies seeking licensing. Link to MAS Homepage here AUSTRALIA ASIC Review Finds Greater Uplift Needed in Quality of Super Fund Financial Reports and Audits On 30 September 2025, the Australian Securities & Investments Commission (ASIC) published its first report into the financial reporting and audit of super funds, which revealed inconsistent approaches to disclosing investments, limited disclosure of sponsorship and advertising expenses, and insufficient audit evidence obtained in the valuation of some investments. Report 816 “Accounting for your super: ASIC’s review into the financial reporting and audit of super funds” reveals the findings from ASIC’s review of financial reports from sixty registrable superannuation entities (RSEs) for the year ended 30 June 2024 and five RSE audit files. ASIC’s review focused on the valuation and disclosure of investments and the disclosure of expenses. REP 816 is the first in a series of three reports examining financial reporting and audit quality in 2024-25. ASIC says it will publish a report on auditor independence in early October, followed by its annual financial reporting and audit public report in late October. Valuation and disclosure of investments ASIC’s review found RSEs took different approaches when categorising unlisted investments in the fair value hierarchy, often with limited disclosure about their approach. These different approaches meant it was difficult for a report user to compare investments between RSE financial reports, or to understand howmuch they could rely on those valuations. Disclosure of sponsorship and advertising expenses ASIC’s review also found that sponsorship and advertising expenses were not separately disclosed in some financial reports because RSEs took a narrow, quantitative approach to materiality.

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