Global Trustee and Fiduciary Services Bite-Sized Issue 2 2025

17 QUICK LINKS BENCHMARKS REGULATION CRYPTOASSETS DORA EMIR FSB MIFID II/MIFIR MMF SUSTAINABLE FINANCE/ESG T+1 ASIA EUROPE INTERNATIONAL LUXEMBOURG NETHERLANDS NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 2 | 2025 In relation to its AFM Agenda 2025, under supervision of asset management, the AFM lists three priorities: • Priority 1: Asset managers increase the maturity level of digital resilience; • Priority 2: Managing sustainability risks; and • Priority 3: Intensive cooperation in Europe. Link to AFM Trend Monitor 2025 here Link to AFMAgenda 2025 here NORTH AMERICA SEC Announce Extension of Form PF Amendments Compliance Date On 29 January 2025, the Securities and Exchange Commission (SEC), together with the Commodity Futures Trading Commission (CFTC), extended the compliance date for the amendments to Form PF that were adopted on 8 February 2024. The compliance date for these amendments, which was originally 12 March 2025, has been extended to 12 June 2025. Form PF is the confidential reporting form for certain SEC-registered investment advisers to private funds, including those that also are registered with the CFTC as commodity pool operators or commodity trading advisers. The SEC says that the extension will mitigate certain administrative and technological burdens and costs associated with the prior compliance date. The extension will also provide more time for filers to program and test for compliance with these amendments. Link to SEC Press Release here UNITED KINGDOM FCA Handbook Notice 126: Collective Investment Schemes Sourcebook (Concentration Limits) Instrument 2025 On 31 January 2025, the Financial Conduct Authority (FCA) published Handbook Notice 126. The FCA says that following consultation in CP24/11, the FCA Board has made changes to the Handbook sections COLL 5.2 and COLL TP 1.1 In summary, the FCA says, that this instrument makes changes to an existing rule that sets limits on the ability of a UCITS scheme to hold units of other collective investment schemes (“second schemes”). The rule aims to reinforce appropriate risk diversification in a UCITS fund of funds. Under the clarified rules, sub-funds of an umbrella UCITS can hold up to 25% (by value) of units issued by a second scheme. The term second scheme is also clarified to include the sub-fund of an umbrella scheme. The FCA says that the changes clarify how the rule applies to umbrella/sub-fund structures. The amendments also disapply the concentration rule in certain situations where the investing UCITS scheme and second scheme are managed by the same firm. This instrument came into force on 31 January 2025 and firms have until 30 January 2026 to ensure they comply with the clarifications. Link to Handbook Notice 126 here Link to Instrument here