Global Trustee and Fiduciary Services Bite-Sized Issue 3 2025

15 QUICK LINKS CRYPTOASSETS CSDR EMIR FINTECH FSB OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE IRELAND LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 3 | 2025 NORTH AMERICA SEC Extends Compliance Dates and Provides Temporary Exemption for Rule Related to Clearing of U.S. Treasury Securities On 25 February 2025, the Securities and Exchange Commission (SEC) extended the compliance dates for Rule 17ad-22(e)(18)(iv)(A) and (B) under the Securities Exchange Act by one year to 31 December 2026, for eligible cash market transactions, and 30 June 2027, for eligible repo market transactions. Under the rule, a covered clearing agency that provides central counterparty services for U.S. Treasury securities must establish, implement, maintain, and enforce written policies and procedures reasonably designed to require that every direct participant of the covered clearing agency submit for clearance and settlement all eligible secondary market transactions in U.S. Treasury securities to which it is a counterparty. The rule also requires a covered clearing agency to identify and monitor its direct participants’ submissions of transactions for clearing, including how the covered clearing agency would address a failure to submit transactions. The SEC also issued a temporary exemption regarding Exchange Act Rule 17ad-22(e)(6)(i). This rule requires that covered clearing agencies have written policies and procedures reasonably designed to calculate, collect, and hold margin amounts from a direct participant for its proprietary positions in U.S. Treasury securities separately and independently frommargin calculated and collected from that direct participant in connection with U.S. Treasury securities transactions by an indirect participant that relies on the services provided by the direct participant to access the U.S. Treasury securities covered clearing agency’s payment, clearing, or settlement facilities. Under this temporary exemption, a U.S. Treasury securities covered clearing agency is not required to enforce its written policies and procedures regarding Rule 17ad-22(e)(6)(i) until 30 September 2025, instead of the original 31 March 2025, compliance date. The extension will provide additional time for further engagement on compliance, operational, and interpretive questions, and facilitate an orderly implementation of the rules. The temporary exemption allows covered clearing agencies not to enforce policies and procedures established pursuant to Rule 17ad-22(e)(6)(i) against any market participants currently clearing indirect participant activity that are not ready to comply with such policies and procedures, but it does not affect the ability of a covered clearing agency to implement such policies and procedures for those that are prepared to comply. If a direct participant of a U.S. Treasury covered clearing agency determines to offer certain access models or segregated margin accounts, the covered clearing agency would be obligated to enforce those rules regarding such models or accounts against the relevant participant, and the direct participant must comply with those rules. Link to Updated Final Rule here Link to Exemptive Order here SEC Issues Exemption From Exchange Act Rule 13f-2 and Related Form SHO On 7 February 2025, the SEC provided a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act and from reporting on Form SHO. As a result of the exemption, filings on initial Form SHO reports from institutional investment managers that meet or exceed certain specified thresholds will be due by 17 February 2026, for the January 2026 reporting period. The effective date for Rule 13f-2 and Form SHO was 2 January 2024, and the compliance date for such rule and formwas 2 January 2025, with initial Form SHO filings originally due by 14 February 2025. Rule 13f-2 requires institutional investment managers that meet or exceed certain specified thresholds to file Form SHO with the SEC within 14 calendar days after the end of each calendar month with regard to certain equity securities via the SEC’s Electronic Data Gathering, Analysis, and Retrieval System (EDGAR). The SEC will publish, on an aggregated basis, certain information regarding each equity security reported by institutional investment managers on Form SHO and filed with the SEC via EDGAR. This exemption will provide industry participants sufficient time to work with SEC staff to address any outstanding operational and compliance questions. This exemption will also provide filers sufficient time to complete implementation of system builds and testing.