Global Trustee and Fiduciary Services Bite-Sized Issue 12 2025

21 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 Prudential Regulatory Reporting by MIFIDPRU Investment Firms – Data Quality Review On 26 November 2025, the FCA published its findings on the data quality of prudential regulatory reporting of MIFIDPRU investment firms, including its expectations, good practice and areas for improvement. In this recent review, the FCA said it found that most firms understand their MIFIDPRU reporting requirements – around 60% of firms passed all its data quality tests. The FCA said it also saw good practice in reporting across time periods and cross-validation across returns. However, the FCA identified areas of improvement for firms: • Inconsistent reporting across multiple data sources; • Inaccurate implementation of reporting guidance; • Incorrect reporting of type of investment firm; and • Incorrect reporting units and data entry issues. The FCA said that firms should compare its findings to their arrangements to see if they meet the FCA’s expectations. The FCA said that it is not setting new reporting requirements or guidance and that the findings aim to help firms better understand the FCA’s existing expectations, identify any issues and make improvements. Link to the Review here FCA Publishes Transaction Reporting Proposals On 21 November 2025, the FCA published a consultation on its plans to streamline MiFID transaction reporting requirements. With the aim of reducing costs for firms, support growth and improve the quality of data received, the FCA has proposed: • Removing foreign exchange derivatives from reporting requirements; • Removing reporting requirements for 6 million financial instruments including equities, bonds and certain derivatives that are only traded on EU trading venues; and • Reducing the period for correcting historic reporting errors from 5 to 3 years. The FCA estimates the proposed changes will result in a net annual cost saving to industry of GBP 108m. The FCA said that, as part of the new long-term approach to transaction reporting, it will work with the Bank of England and HM Treasury to streamline requirements and reduce duplication across different data collections, including UK MiFIR, EMIR and SFTR. Link to Consultation here FCA Review Finds CFD Providers may be Failing to Deliver Fair Value to Consumers On 13 November 2025, the FCA published findings from its multi-firm review of contracts for difference (CFD) providers’ provision of price and value. Under the Consumer Duty, CFD firms must ensure the price a consumer pays is reasonable, compared to the overall benefits they can reasonably expect to receive. The FCA’s review of CFD providers assessed how a range of large and small firms delivered fair value, including how costs and charges were disclosed. The FCA said that some good practice was in evidence, including firms simplifying fee structures and stopping investors who might not be able to shoulder losses from buying CFDs in the first place. However, the FCA said its review found room for improvement, including where firms were: • Not adequately considering consumer complaints or customer satisfaction as part of their fair value assessments;