Global Trustee and Fiduciary Services Bite-Sized Issue 7 2025

14 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 The SEC says that 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 states that this extension will provide more time for filers to program and test for compliance with these amendments. Link to Joint Final Rule Compliance Extension here Link to CFTC Announcement here Link to SEC Chair Atkins’ Statement here SEC Solicits Public Comment on the Foreign Private Issuer Definition On 4 June 2025, the SEC published a concept release soliciting public comment on the definition of foreign private issuer. The SEC says that foreign private issuers benefit from certain accommodations and exemptions from the disclosure and filing requirements of the federal securities laws. The concept release solicits public input on whether the definition of foreign private issuer should be amended in light of significant changes in the population of foreign private issuers since 2003. In this concept release, the SEC says that it welcomes comments on the current foreign private issuer definition as well as on the costs, burdens, or benefits that may result from possible regulatory responses. The public comment period will remain open for 90 days following publication of the comment request in the Federal Register. Link to Concept Release here Link to Fact Sheet here UNITED KINGDOM FCA Publish Policy Statement on PISCES On 10 June 2025, the Financial Conduct Authority (FCA) published its Policy Statement: Private Intermittent Securities and Capital Exchange System (PISCES): sandbox arrangements (PS25/6). PS25/6 follows on from the FCA’s consultation that was launched in December 2024. In a press release issued the same day as PS25/6, the FCA have said that PISCES will open the door to more opportunities for investors, facilitating their access to growth companies. Private companies can tap into a broader range of investors and asset managers and PISCES offers exits for shareholders to sell up. And, as companies choose to stay private for longer, then the FCA says that there is demand for investors to trade private company shares easily and efficiently in an organised marketplace. Access to PISCES will be limited to institutional investors, high-net-worth individuals, sophisticated investors and employees of participating companies. Investors will be provided with information about the risks involved to help themmake informed decisions. In PS25/6, the FCA have published rules for entities hosting a PISCES platform (operators), including on: • Disclosure arrangements; • Organising and running trading events; and • Market manipulation and oversight. To test this regulatory framework, the FCA have committed to running a sandbox until June 2030.