Global Trustee and Fiduciary Services Bite-Sized Issue 10 2026

18 AIFMD CRYPTOASSETS FINTECH FUND LIQUIDITY OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 10 | 2026 Quick Links Expanded Ability for Multiple Share Class Closed-End Funds The proposal would amend certain rules under the Investment Company Act to permit regulated closed-end funds to have multiple share class structures and allow them and their affiliates to enter into arrangements for the payment of asset-based distribution and service fees. The SEC says the proposal would update required prospectus disclosures to account for multiple share class andmaster feeder structures in regulated closed-end funds, and update certain reporting forms to enhance multiple share class reporting by certain regulated closed-end funds. The proposal would also require enhanced expense disclosures regarding all regulated closed-end funds. As a result of the proposed amendments, the SEC has proposed to rescind certain existing exemptive orders related to interval funds and multiple share class arrangements for regulated closed-end funds. SEC Seeks Public Comment on Additional Ways to Qualify as an Accredited Investor Separately, the SEC is seeking comments on the potential designation of the passage of an accredited investor exam to be developed by the Financial Industry Regulatory Authority (FINRA) as an additional method for investors to be accredited investors. An examwould provide a non- financial pathway for investors to demonstrate their sophistication in the areas of securities, investing, and financial and business matters to appropriately evaluate the merits and risks of a prospective investment. The SEC also seeks comment on the potential designation of holding, in good standing, certain licenses, certifications, or other credentials as additional ways for individuals to qualify as accredited investors. Among the designations the SEC is considering: • A license as a U.S. certified public accountant (CPA); • A charter as a Chartered Financial Analyst (CFA); • A certification as a Certified Financial Planner (CFP) in the United States; • The FINRA Investment Banking Representative license (Series 79); and • The FINRA Research Analyst license (Series 86 and Series 87). The public comment periods will remain open for 60 days after the date of publication of the proposing releases and the notices in the Federal Register. Link to Fact Sheet: Expanding Retail Investor Choice and Promoting Innovation in Regulated Fund Structures here Link to Proposed Rule: Investment Adviser Performance-BasedCompensationModernization here Link to Proposed Rule: Interval Fund Modernization; Expansion of Multiple Share Class to Registered Closed-End Management Investment Companies and Business Development Companies here Link to Potential Designation of Passage of an Accredited Investor Exam to Be Developed by FINRA as Qualifying Natural Persons for Accredited Investor Status here SEC “Innovation Exemption” to Facilitate the Trading of Tokenized NMS Stock and Request for Comment On 17 September 2026, the SEC issued an order granting temporary, conditional exemptive relief to Tokenized Securities Venues (TSVs) from the definition of “exchange” in the Securities Exchange Act of 1934 (Exchange Act) to trade tokenized National Market System (NMS) stock using innovative permissioned automated market makers and liquidity pools (AMM Liquidity Pools). TSVs bring together buyers and sellers of tokenized NMS stock by: (1) providing one or more AMM Liquidity Pool(s) for permissioned participants to interact and agree to terms of a trade, and (2) setting standards for persons to access trading on such AMM Liquidity Pool(s).