Global Trustee and Fiduciary Services Bite Sized Issue 8 2025

16 QUICK LINKS CBDC CRYPTOASSETS CSDR EMIR FINTECH FSB OPEN FINANCE OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG ASIA PACIFIC NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 8 | 2025 FCA to Modernise Rules to Unlock Investment On 10 July 2025, the FCA announced that it is planning to review its client categorisation rules to unlock more opportunities for wealthy investors and support capital markets, driving economic growth. The FCA says that reviewing the rules will ensure that expectations remain proportionate when dealing with wealthy or very experienced investors and that it should give confidence to firms and support investment in capital markets, boosting the competitiveness of financial services. The FCA says that it will be consulting on the elective professional client categorisation later this year. Link to Announcement here Growth of Private Markets Inquiry Launched On 2 July 2025, the Financial Services Regulation Committee (the Committee) launched an inquiry into the growth of private markets in the UK following reforms introduced after 2008. The inquiry will investigate the growth of private markets in the UK following the reforms. In particular, the inquiry will examine whether the regulatory capital and liquidity reforms introduced after 2008 have reduced banks’ ability or willingness to lend, pushing risk away from the banking sector and towards private markets. It will also look at howmuch visibility the Bank of England (BoE) has on the size of these private markets, their interconnections with the banking sector, and any potential spillover risks. The Committee will explore: Whether bank lending to the real economy in the UK has reduced as a proportion of the total volume of finance provided annually since 2008, and whether this change can be attributed to the reforms to the UK’s regulation of bank capital and liquidity requirements. What interconnections exist between the UK’s banking sector and private markets and how these have changed since 2008. What the implications of the growth in private markets, and their interconnections with the wider financial services sector, are for lending to the real economy and for the UK’s financial stability. • Whether the BoE has sufficient visibility regarding non-bank finance, and what changes, if any, should be made to address this. • Whether there are systemic risks that the BoE should be aware of regarding non-bank financial intermediation, and, if so, how these risks can be mitigated. • How demand for finance from businesses has changed since 2008 and how it may develop in the future. • To what extent private markets have a competitive advantage over the banking sector to provide finance to businesses, and, if so, to what extent these may be regulatory in nature. • What, if any, reforms to bank capital regulation could be implemented to increase the risk appetite of the banking sector to provide lending to the real economy. • What the UK could learn from other jurisdictions, in particular the U.S. and the EU. The response period for submissions to the inquiry closes on 18 September 2025. Link to Inquiry here FCA Clarifies Expectations on Bullying, Harassment and Violence to Deepen Trust in Financial Services On 2 July 2025, the FCA published a Consultation Paper (CP25/18) on tackling non-financial misconduct in financial services which includes a Policy Statement on amendment to the Code of Conduct (COCON) following CP23/20. In CP25/18 the FCA is seeking views on whether any additional Handbook guidance is needed to help firms meet their obligations under its rules.