Global Trustee and Fiduciary Services Bite-Sized Issue 7 2025

13 QUICK LINKS AIFMD CSDR ELIGIBLE ASSETS DIRECTIVE EMIR FINTECH FSB MIFID II/MIFIR SUSTAINABLE FINANCE/ESG VIRTUAL ASSETS ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 7 | 2025 NORTH AMERICA SECOffice of the Investor Advocate Delivers to Congress Report onObjectives for Fiscal Year 2026 On 25 June 2025, the Securities and Exchange Commission’s (SEC) Office of the Investor Advocate delivered its Report to Congress on the office’s objectives for fiscal year 2026. As detailed in the report, the Investor Advocate’s priorities for fiscal year 2026 include: • Investor research and testing on existing and proposed disclosures to retail investors; • Informing SEC activities and policy priorities through data collected from nationally representative surveys; • Addressing and advocating for the priorities and concerns of retail investors affected by financial fraud, including through the Interagency Securities Council; • Private market investments in retirement accounts; and • China-based variable interest entities listed on U.S. exchanges. Link to Report here SECWithdraws Notice of Fourteen Proposed Rules Effective 17 June 2025, the SEC announced the withdrawal of 14 notices of proposed rulemaking issued between March 2022 and November 2023 and stated that it does not intend to issue final rules with respect to these proposals. The SEC states that if it decides to pursue future regulatory action in any of the areas covered by a withdrawn rule, it will issue a new proposed rule. One proposal was related to the Division of Corporation Finance: Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule 14a-8 (July 27, 2022), which sought to amend the substantial implementation, duplication, and resubmission exclusions for shareholder proposals. Thirteen proposals related to the Division of Investment Management and the Division of Trading Markets, several of which had the potential to significantly impact investment companies and their asset managers, including: • Safeguarding Advisory Client Assets (9 March 2023): This proposed rule focused on how investment advisers safeguard client assets, including amending the custody rule. This would have directly affected asset managers’ responsibilities and procedures for managing client funds. • Cybersecurity Risk Management for Investment Advisers, Registered Investment Companies, and Business Development Companies (9 March 2022): This proposal aimed to enhance cybersecurity practices for investment advisers and investment companies. Asset managers would have needed to implement new policies and procedures to comply with these requirements. • Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social and Governance Investment Practices (17 June 2022): This proposal would have required additional disclosures regarding ESG investment practices, impacting how asset managers communicate their ESG strategies and potentially influencing investment decisions. • Outsourcing by Investment Advisers (16 November 2022): This proposed rule aimed to regulate the outsourcing practices of investment advisers, affecting how asset managers delegate certain functions and requiring greater oversight of third-party service providers. Link to Notice of Formal Withdrawal here Further Extension of Form PF Amendments Compliance Date On 11 June 2025, the SEC, together with the U.S. Commodity Futures Trading Commission (CFTC), voted to extend the compliance date until 1 October 2025, for the amendments to Form PF that were adopted on 8 February 2024. The compliance date for these amendments was originally 12 March 2025, but was previously extended to 12 June 2025.