Global Trustee and Fiduciary Services Bite-Sized Issue 3 2025

16 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 Transparency is essential to well-functioning markets. And the SEC has stated the importance of providing more disclosure about short selling. It is also important to enhance the accuracy of the short sale-related data that would ultimately be provided to investors by giving institutional investment managers additional time. Rule 13f-2 and Form SHO reporting will enhance the transparency of other available short sale- related information. Currently, several self-regulatory organizations (SROs) are providing on their websites daily aggregate short selling volume information for individual equity securities. The SROs are also providing website disclosure on a one-month delayed basis of information regarding individual short sale transactions in all exchange-listed equity securities. Hyperlinks to short sale data provided by specific SROs are available. Further, the SROs are also publishing monthly statistics on short interest in securities that trade on their markets. Additionally, the SEC publishes on its website failures to deliver data for all equity securities, regardless of the fails level, twice per month. Link to SEC Exemptive Order here UNITED KINGDOM FCA: Growth of Private Markets Requires Continued Focus on Valuations On 5 March 2025, the Financial Conduct Authority (FCA) published its review of private market valuation processes following its multi-firm assessment of valuation practices and governance for valuing private equity, venture capital, private debt, and infrastructure assets. The FCA says firms generally demonstrated good practice in areas such as investor reporting, process documentation and use of third-party valuation advisers, and were consistently applying valuation methodologies. However, the FCA says it found areas where firms need to improve. These included the need for better identification and documentation of potential conflicts of interest in the valuation process, and increased independence within firms’ own valuation processes. The FCA says it also found that some firms needed to enhance processes for ad hoc valuations in times of market disruption. The FCA says its findings will be used in its review of the onshored Alternative Investment Fund Managers Directive (AIFMD) as it updates its rules in the Handbook and will inform the FCA’s contribution to IOSCO’s review of global valuation standards to support the use of proportionate and consistent valuation standards globally in private markets. Link to Review here Consumer Duty Board Champions On 27 February 2025, the FCA updated its webpage “Consumer Duty – information for firms” to reflect the decision to provide firms with greater flexibility on their ongoing governance arrangements and therefore the FCA no longer expects them to have a Consumer Duty champion, although they can retain the role should they wish to do so. The FCA has made this decision as it believes the Consumer Duty should now be well-embedded in firms’ management discussions, processes, and policies. The FCA’s rules require firms to ensure that their obligations under the Consumer Duty are reflected in their strategies, governance, leadership and people policies, including incentives at all levels. Firms also need to ensure that retail customer outcomes remain central to the firm’s risk control arrangements and internal audit function. Link to UpdatedWebpage here