Global Trustee and Fiduciary Services Bite-Sized Issue 10 2026

19 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 The exemption from the definition of “exchange” for TSVs is subject to conditions designed to ensure the exemptive relief is in the public interest and consistent with the protection of investors, including that: • Tokenized NMS stocks traded on a TSV are subject to limits on the number of symbols and volume traded; • A TSV must verify that the tokenized NMS stock made available for trading on the TSV provides holders the same rights and privileges as traditional NMS stock of an equivalent class; • Before making available for trading a tokenized NMS stock that is tokenized by an unaffiliated third party, the TSV must provide written notice and an opportunity to object to the issuer of the underlying NMS stock; • Smart contracts used by a TSV must be auditable, public, and deployed on a public, permissionless distributed ledger; • A TSV must stop trading in a tokenized NMS stock concurrently with any stoppage of trading in the underlying NMS stock on the primary listing exchange; and • A TSV must provide public notice about its operations, trading activities, and the trading activities of its affiliates on the TSV. In addition, the order also will temporarily grant a conditional exemption from the definition of “dealer” as defined in section 3(a)(5) of the Exchange Act to liquidity providers in an AMM Liquidity Pool used by a TSV that supply liquidity in the form of tokenized NMS stock using proprietary capital and may also be engaged in additional activities that are indicia of dealing activity, such as quoting pricing to customers or entering into agreements to provide committed capital. The exemptions are set to expire five years after publication. The order solicits public comment about possible modifications to the exemptive relief and potential next steps. The order will be published on SEC.gov and in the Federal Register. Link to Exemptive Order here Link to Fact Sheet here SEC Proposes Rescission of Shareholder Proposal Rule and Reforms to Proxy Solicitation Process On 16 September 2026, the SEC proposed the rescission of Rule 14a-8 under the Securities Exchange Act of 1934, which would leave determinations about the role of shareholder proposals to state law and company governing documents. Rule 14a-8, the shareholder proposal rule, addresses when companies must include shareholder proposals in their proxy materials. The SEC says rescinding the rule would leave those determinations to state law and company governing documents (if permitted by state law). The SEC says the proposed amendments to Rule 14a-4(c) would provide companies with greater flexibility to seek and obtain discretionary voting authority regarding shareholder proposals submitted outside of Rule 14a-8, the submission of which may become more frequent if Rule 14a-8 is rescinded, as proposed. At the same time, the proposed amendments would provide shareholders with the ability to elect to prevent the company from exercising such authority with respect to their individual shares. The SEC separately proposed rule amendments to modernize the proxy solicitation process. Reflecting advancements in technology and current realities of shareholder communications, those amendments would: • Eliminate the requirement that companies deliver an annual report to security holders; • Eliminate the delivery deadline when documents are incorporated by reference into a proxy statement; • Eliminate the requirement and the ability to submit Notices of Exempt Solicitation; and • Shorten the minimum broker search period from 20 business days to five business days.