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

6 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 MAS says that in considering early withdrawals of deposits, an MMF should also consider pertinent factors such as penalties or other costs associated with the early withdrawal of deposits. The consultation closes on 28 February 2026. Link to MAS Homepage here FCA Consults on Enhancing Fund Liquidity Risk Management On 9 December 2025, the Financial Conduct Authority (FCA) published CP25/38 – Enhancing Fund Liquidity Risk Management. The FCA says that it is asking for feedback on its proposals to make sure authorised fund managers (AFMs) have the right tools and systems to manage their funds’ liquidity and use them effectively. The FCA states that its proposals will help make sure AFMs of undertakings for collective investment in transferable securities (UCITS) schemes and non-UCITS retail schemes (NURS) have effective anti-dilution tools to help prevent the value of investors’ investments becoming diluted over time. These proposals will also make sure AFMs of UCITS schemes and NURS, particularly those with portfolios with a high level of less liquid assets, have robust liquidity risk management processes in place. The FCA says that it also proposes to create two new guidance annexes in the Collective Investment Schemes Sourcebook (COLL) which will incorporate key aspects of the IOSCO recommendations and the expectations the FCA have communicated to date on liquidity risk management. The first annex would provide guidance on effective liquidity risk management systems, including when dealing with non-redemption pressures, and the second is an updated version of the existing European Securities and Markets Authority (ESMA) liquidity stress testing guidelines. Whilst the FCA proposes that these annexes apply to AFMs of UCITS schemes and NURS, it says it will consider the application to other alternative investment funds (AIFs) when developing its proposals for the separate CP on reform of the Alternative Investment Fund Managers Directive (AIFMD) regime, scheduled for 2026. The deadline for comments on CP25/38 is 23 February 2026. Link to CP25/38 here MIFID/MIFIR ESMA Finalises Technical Standards on Derivatives Transparency and the OTC Derivatives Tape On 15 December 2025, the European Securities and Markets Authority (ESMA) published a Final Report covering mandates under the MiFIR Review on derivatives trade transparency, package orders and the over-the-counter (OTC) derivatives consolidated tape input and output data. The proposed pre- and post-trade transparency requirements for exchange traded derivatives (ETDs) and OTC derivatives are designed to provide a high level of transparency whilst ensuring that liquidity providers are protected from undue risk. In the final proposals, ESMA says that it has taken on board stakeholders’ feedback to streamline and improve the deferral regime initially proposed in the public consultation, in particular concerning equity ETDs and single-name credit default swaps.