Global Trustee and Fiduciary Services Bite-Sized Issue 1 | 2026

17 QUICK LINKS AI BENCHMARKS REGULATION (UK) CRYPTOASSETS EMIR FSB FUND LIQUIDITY MIFID/MIFIR IOSCO RETAIL INVESTMENT STRATEGY SAVINGS & INVESTMENTS UNION SUSTAINABLE FINANCE/ESG ASIA PACIFIC EUROPE IRELAND NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 1 | 2026 NORTH AMERICA SEC Commissioner Mark T. Uyeda Provides Update on ContinuingWork Toward Treasury Clearing Implementation On 23 December 2025, Securities and Exchange Commission (SEC) Commissioner Uyeda commented on the implementation of the Treasury Clearing rule, which, among other things, mandates the clearing of certain eligible secondary market transactions in U.S. Treasury securities by direct participants in covered clearing agencies. Commissioner Uyeda highlighted the SEC’s order approving a proposed new offering from the Fixed Income Clearing Corporation (“FICC”) to establish a new “Collateral-in-Lieu” service as part of the existing Sponsored General Collateral (GC) Service. Commissioner Uyeda says that this new service will allow FICC to take a lien on the collateral underlying a repo transaction, in lieu of charging margin. The lien, in most instances, will obviate FICC’s need to collect margin or to obtain a guarantee on the transactions. The new service would address what market participants have referred to as “double margining” that increases the costs (and thereby decreases the ability) of a FICC Sponsoring Member to provide clearance and settlement services to registered investment companies and other cash providers. Link to Statement here CFTC Staff Issues No-Action Letter Regarding CPO Registration for Certain SEC-Registered Investment Advisers On 19 December 2025, the Commodity Futures Trading Commission’s Market Participants Division (MPD) announced it has issued a no-action letter to the Managed Funds Association submitted on behalf of its members. The letter states MPD will not recommend the CFTC initiate an enforcement action against firms registered as investment advisers with the Securities and Exchange Commission (SEC), who operate commodity pools privately offered solely to sophisticated investors known as qualified eligible persons, for failing to register with the SEC as a commodity pool operator, subject to certain conditions. Link to Press Release here Statement on the Custody of Crypto Asset Securities by Broker-Dealers On 17 December 2025, the SEC’s staff of the Division of Trading and Markets (the Division) issued a statement providing its views on the application of paragraph (b)(1) of Rule 15c3-3 to crypto assets that are securities (“crypto asset securities”). The Division says that this statement addresses any broker-dealer that carries crypto asset securities for customers, including broker-dealers that conduct a traditional securities business. It adds that the statement was part of an effort to provide greater clarity on the application of the federal securities laws to crypto asset securities. The Division provided its views in response to requests frommarket participants as an interim step while the SEC continues to consider issues relating to a broker-dealer’s custody of crypto asset securities and the feedback it has received. Link to Statement here Additional Observations Regarding Advisers’ Compliancewith the Advisers Act Marketing Rule On 16 December 2025, the SEC’s Division of Examinations (the Division) issued a Risk Alert to provide further information on investment advisers’ compliance with the amended Rule 206(4)-1 (the “Marketing Rule”) under the Investment Advisers Act of 1940. This alert follows a previous one and focuses specifically on observed deficiencies related to the “Testimonials and Endorsements Provisions” and “Third-Party Ratings Provisions” of the Marketing Rule. The Division highlights issues with disclosure requirements, oversight, compliance practices, due diligence, and the appropriate handling of compensation and conflicts of interest.