Global Trustee and Fiduciary Services Bite Sized Issue 10 2025

18 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 Mansion House Commitment on Consumer Duty Application toWholesale Firms On 29 September 2025, the FCA published a letter fromNikhil Rathi, CEO, FCA, to the Chancellor of the Exchequer, outlining the FCA’s plans to address concerns regarding the application of the Consumer Duty to wholesale firms. The FCA acknowledges both the positive impact of the Consumer Duty on consumer protection and the challenges faced by wholesale firms, proposing a four-point action plan to refine its application. The FCA highlights the following points: • Consumer Duty’s Impact and Challenges: The Consumer Duty has enhanced consumer protection, but wholesale firms report disproportionate compliance burdens and lack of clarity, particularly concerning business-to-business activities and non-UK customers. • Action Plan for Clarity and Proportionality : The FCA has committed to an action plan, beginning in late 2025 and extending into 2026, focusing on clarifying supervisory expectations, updating client categorisation, streamlining rules for distribution chains, and potentially removing non- UK customers from the Duty’s scope. • Balancing Protection with Competitiveness : The FCA aims to maintain robust consumer protection while ensuring the UK financial services sector remains competitive by reducing unnecessary regulatory burdens on wholesale firms and fostering innovation. The FCA says it is proactively adjusting the Consumer Duty to better suit wholesale firms, aiming to reduce compliance costs, and provide clearer guidance. Link to Letter here HM Treasury Announces Establishment of Transatlantic Taskforce for Markets of the Future On 22 September 2025, HM Treasury (HMT) announced the establishment of the UK/US Transatlantic Taskforce for Markets of the Future (Taskforce) to enhance collaboration on capital markets, digital assets and other innovative financial activities. The aim of the Taskforce is to report, via the UK – US Financial Regulatory Working Group (FRWG), on recommendations to enhance collaboration on capital markets and digital assets and other innovative financial activities. These recommendations are to be developed in close collaboration with industry partners on both sides of the Atlantic. The Taskforce will explore: 1. Options for short-to-medium term collaboration on digital assets whilst legislation and regulatory regimes are still developing, as well as options for long-term collaboration and additional opportunities for wholesale digital markets innovation. 2. Options to improve links between UK/US capital markets to enhance the growth and competitiveness of both UK and US markets, focusing on reducing burdens for UK and US firms raising capital cross-border. The Taskforce is instructed to report by 21 March 2026. Link to Announcement here