Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

16 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 SEC and CFTC Extend Form PF Compliance Date to 1 October 2026 On 17 September 2025, the SEC and U.S. Commodity Futures Trading Commission (CFTC) each voted to further extend the date for investment advisers to comply with amendments to Form PF, the confidential reporting form used by certain private fund advisers. The SEC and CFTC have extended the compliance date to 1 October 2026. The Form PF amendments were adopted in February 2024 and the original compliance date was 12 March 2025. The compliance date was previously extended to 12 June 2025 and then 1 October 2025, but this further extension will provide time to complete a substantive review of Form PF in accordance with a Presidential Memorandum and take any further appropriate actions, which may include proposing new amendments to Form PF. Link to Final Rule here Link to Statement by SEC Chair Paul S. Atkins here Link to Statement by Commissioner Mark T. Uyeda here Link to Statement by Commissioner Caroline A. Crenshaw here Link to Statement by Commissioner Hester M. Peirce here SEC Approves Generic Listing Standards for Commodity-Based Trust Shares On 17 September 2025, the SEC voted to approve proposed rule changes by three national securities exchanges (The Nasdaq Stock Market LLC (Nasdaq), Cboe BZX Exchange, Inc. (BZX), and NYSE Arca, Inc. (NYSE Arca)) to adopt generic listing standards for exchange-traded products that hold spot commodities, including digital assets. As a result, the exchanges may list and trade Commodity-Based Trust Shares that meet the requirements of the approved generic listing standards without first submitting a proposed rule change to the SEC pursuant to Section 19(b) of the Securities Exchange Act of 1934. Link to Proposed Rule here Link to Statement by Commissioner Caroline A. Crenshaw here Link to Statement by Commissioner Hester M. Peirce here SEC and CFTC Staff Issue Joint Statement on Trading of Certain Spot Crypto Asset Products On 2 September 2025, Staff of the SEC and the CFTC issued a Joint Statement regarding the trading of certain spot crypto asset products. This Joint Statement clarifies staff ’s views that SEC- and CFTC-registered exchanges are not prohibited from facilitating the trading of certain spot commodity products. The Joint Statement follows recommendations from the President’s Working Group on Digital Asset Markets report on “Strengthening American Leadership in Digital Financial Technology.” The report recommended that the SEC and CFTC coordinate to make America the best place in the world to innovate with blockchain technology and participate in crypto asset markets. The Divisions of Trading and Markets at the SEC and Market Oversight and Clearing and Risk at the CFTC identified various considerations for market participants seeking to operate crypto markets and trade in spot crypto asset products. These include margin, clearing, and settlement; monitoring of underlying markets; sharing of reference pricing venues by National Security Exchanges (NSEs), Designated Contract Markets (DCMs), and Foreign Boards of Trade (FBOTs); and public dissemination of trade data. The Joint Statement and more information regarding the SEC’s and CFTC’s efforts in this area are available on the agencies’ websites. Link to Joint Statement here Link to Statement by SEC Chair Paul S. Atkins and Acting CFTC Chair Caroline D. Pham here