Global Trustee and Fiduciary Services Bite-Sized Issue 9 2025

14 QUICK LINKS CRYPTOASSETS CYBERSECURITY EMIR (UK) FINTECH MIFID/MIFIR (UK) SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC AUSTRALIA EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 9 | 2025 • Statistics Download: all available statistics in the table and data visualizations; and • Related Materials: research and reports, regulatory background, investor bulletins, or additional resources. The new webpage can be found on the SEC’s website under Data & Research. Link to Statistics and Data Visualizations Webpage here Democratizing Access to Alternative Assets for 401(k) Investors On 7 August 2025, U.S. President Donald Trump issued an executive order titled Democratizing Access to Alternative Assets for 401(k) Investors. Among other things, the order directs the U.S. Secretary of Labor to review fiduciary guidance on private market investments in 401(k) and other defined contribution plans governed by the Employee Retirement Income Security Act. On 12 August 2025, the U.S. Department of Labor’s Employee Benefits Security Administration rescinded a supplemental statement issued in 2021 that discouraged fiduciaries from considering alternative assets in 401(k) retirement plan investment menus. Link to Executive Orders here Link to U.S. Department of Labor News Release here UNITED KINGDOM FCA Publishes IFPR Newsletter On 1 September 2025, the Financial Conduct Authority (FCA) published a Newsletter on the Investment Firms Prudential Regime (IFPR). The first topic covered by the FCA in its Newsletter is ‘Notification when there are changes to an investment firm group.’ Here, the FCA says that under the IFPR, MIFIDPRU firms are required to inform the FCA as soon as they become aware of the creation of an investment firm group (IFG) or a change to their existing investment firm group. The FCA says that this is set out in MIFIDPRU 2.4.20R with a notification to be made via Connect using the MIFIDPRU 2 Annex 8R form. In the event of a change in control, firms are still required to submit this form once any acquisitions have been completed. The FCA says that the timely submission of the MIFIDPRU 2 Annex 8R form ensures its systems hold accurate and up to date information, which enables the effective supervision of groups and oversight of individuals firms group relationship. The FCA also remind firms that they should ensure the data held by the FCA on their group is accurate. Other topics also covered in the Newsletter by the FCA are: • Common equity tier 1 items of limited liability partnerships; • Calculation of certain K-factors, such as the assets under management (K-AUM) requirement; • ICARA submission and common errors in MIF007 reporting; and • Accounts submissions – small companies exemption and MiFID investment firms. Link to IFPR Newsletter here FCA Consumer Duty Update – 2nd Anniversary On 27 August 2025, the FCA marked the two-year anniversary of the Consumer Duty being introduced for open products. In its update, the FCA says that the Consumer Duty is already making a tangible difference and helping people to navigate their financial lives. The FCA states that more can be found out about its impact across markets from FCA Directors: • Emad Aladhal, Director of Retail Banking – Two years of the Consumer Duty – rising to the challenge.