Global Trustee and Fiduciary Services Bite Sized Issue 10 2025
9 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 • Amendments to CSDR Article 75 that would require the European Commission to review the effect of the securities financing exemptions by 17 January 2029. The proposals were republished by the EU Council, on 17 September 2025, prior to their possible amendment or formal adoption. Link to Proposed Regulation here ASIA Concurrent SFC-HKMA Thematic Review of the Distribution of Non-exchange Traded Investment Products On 29 September 2025, the Securities and Futures Commission (SFC) and the Hong Kong Monetary Authority (HKMA) issued a circular announcing that they will commence a new round of concurrent thematic review of the distribution of non-exchange traded investment products by intermediaries. The 2024 SFC-HKMA joint product survey released on 4 September 2025 (see below) showed that all major investment product types recorded significant sales growth last year, with collective investment schemes (CIS) rising by 76% year-on-year. SFC and HKMA said that the upcoming concurrent thematic review will examine selected intermediaries’ policies and procedures, systems and controls, andmanagement oversight concerning the distribution of CIS. The objectives of this review include evaluating intermediaries’ compliance with the suitability requirement under the Code of Conduct, including their practices in performing product due diligence, conducting suitability assessments and providing information to clients. The SFC and the HKMA said that they will share the findings of the upcoming concurrent thematic review with the industry and consider the need for further guidance where appropriate. Link to Circular here MAS Introduces Initiatives to Promote Responsible Online Financial Content, Issues Advisory Letters to Content Creators On 25 September 2025, the Monetary Authority of Singapore (MAS) announced initiatives to promote responsible online financial content sharing and advertising. MAS has published new Guidelines on Standards of Conduct for Digital Advertising Activities (Guidelines) to establish expectations for financial institutions on responsible and professional digital advertising practices. MAS has also issued a guide for online content creators. Guidelines on Standards of Conduct for Digital Advertising Activities MAS says that the Guidelines establish safeguards that financial institutions are expected to adopt to manage risks associated with digital advertising. They apply to all financial institutions and their appointed third parties, including online content creators. Key safeguards include managing the challenges and limitations of digital media, ensuring clear disclosures, as well as setting appropriate policies and procedures to monitor digital advertising activities. The Guidelines are effective from 25 March 2026. MAS & ASAS Guide on sharing financial information online To guide content creators on responsible financial content creation, MAS says it has collaborated with the Advertising Standards Authority of Singapore (ASAS) to develop a guide on “7 must- knows when sharing financial information online”. MAS says that it covers key considerations when creating content – such as when a licence fromMAS may be required, steps to take before promoting an entity’s products or services, and the disclosure of compensation received. Advisory Letters MAS says it will also issue advisory letters to five content creators who may have provided financial advice without a licence. They have been advised to adjust their content and practices to be in line with MAS’ regulatory requirements. MAS says that persons who continue to provide financial advice without a licence will face enforcement action. Link to MAS Homepage here
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