Global Trustee and Fiduciary Services Bite-Sized Issue 12 2025

19 QUICK LINKS COSTS & CHARGES CRYPTOASSETS FINTECH FSB IOSCO OPERATIONAL RESILIENCE SAVINGS AND INVESTMENT UNION SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 12 | 2025 The interpretation provides legal certainty regarding the requirements of CFTC Regulation 30.7, which the staff believes will reduce market participants’ costs in these foreign markets and address certain competitive disadvantages that FCMs experience with respect to customers trading on foreign markets. MPD issued the letter in response to a request from the Futures Industry Association. Link to Staff Letter 25-28 here SEC Publishes Notice Seeking Comment on the Nasdaq Stock Market’s Proposal to Adopt Rule 5703 On 19 November 2025, the SEC published a notice and order to solicit comments on the proposed rule change from interested persons and to grant approval of the proposed rule change on an accelerated basis. Nasdaq Stock Market (the Exchange) proposes to adopt Rule 5703 to permit the generic listing and trading of Class Exchange-Traded Fund (ETF) Shares. The purpose of Rule 5703 is to permit the generic listing and trading, or trading pursuant to unlisted trading privileges, of Class ETF shares. The Exchange is also proposing to make conforming changes to Rule 5615 (Exemptions from Certain Corporate Governance Requirements), Rule 5705(b) (Index Fund Shares), Rule 5735 (Managed Fund Shares), and Equity 4, Rule 4120 in order to accommodate the proposed listing of Class ETF Shares. Link to Notice here Various Regulatory Organizations Submit Letter with Comments to the SEC Requesting to Extend Compliance Deadlines for Regulation S-P Amendments On 19 November 2025, SIFMA, SIFMA AMG, American Bankers Association (ABA), Bank Policy Institute (BPI), Committee of Annuity Insurers (CAI), Financial Services Institute (FSI), Institute of International Bankers (IIB), Investment Adviser Association (IAA), Investment Company Institute (ICI), and the Insured Retirement Institute (IRI), provided comments to the SEC requesting to extend the compliance deadlines for the Regulation S-P amendments (Regulation S-P Amendments) for larger and smaller entities by an additional six months each. The various organizations request the extension to ensure that firms can fully operationalize the Regulation S-P Amendments in a way that is sound, scalable, and aligned with the SEC’s expectations, given the significant operational and technological work required to implement the amendments. Link to Letter here SEC’s Division of Examinations Released its 2026 Examination Priorities On 17 November 2025, the SEC’s Division of Examinations released its 2026 examination priorities. The Division publishes its annual examination priorities to provide transparency to registrants and investors about the topics that the Division plans to focus on in the new fiscal year and to encourage firms to direct their compliance efforts on areas of potentially heightened risk. For fiscal year 2026, in addition to conducting examinations in core areas such as fiduciary duty, standards of conduct, and the custody rule, the Division will continue to focus on the effectiveness of compliance programs, as well information security and operational resiliency. The Division will also examine for compliance with new rules, such as the 2024 amendments to Regulation S-P. As with previous years, the Division will prioritize examinations of newly registered advisers and investment companies to empower and encourage building robust compliance programs. The 2026 examination priorities cover a broad landscape of potential risks to investors that firms should consider as they review and strengthen their compliance programs. They are not, however, an exhaustive list of all the areas the Division will focus on in the upcoming year. The scope of any examination includes analysis of other risk factors such as an entity’s history, operations, and products and services. Link to 2026 Exam Priorities here