Global Trustee and Fiduciary Services Bite-Sized Issue 10 2026

20 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 public comment period closes on 20 November 2026 . Link to Proposed Rule: Rescission of Rule 14a-8’s Federal Regulation of Shareholder Proposals and Amendments to Rule 14a-4 here Link to Fact Sheet here Link to Proposed Rule: Proxy Solicitation Modernization here Link to Fact Sheet here Examinations Observations Regarding Investment Adviser Annual Compliance Review On 14 September 2026, the SEC’s Division of Examinations (the Division) published a Risk Alert relating to the requirement that advisers conduct a review of their compliance policies and procedures at least annually to assess their adequacy and the effectiveness of their implementation. In the Risk Alert the Division highlights certain areas advisers may want to consider when conducting their reviews. It also encourages advisers to reflect upon their practices, policies and procedures and to implement appropriate modifications to their annual review processes. Key Findings The Division says its examinations revealed consistent issues across advisory firms, primarily in six areas: 1. Untimely Reviews : Advisers often failed to conduct annual reviews within the required timeframe, with gaps in review years or extended periods between assessments. 2. Incomplete Procedures : Compliance policies lacked sufficient detail or clear procedures for personnel to effectively perform annual reviews. 3. Inconsistent Execution : Reviews were frequently not performed in accordance with the firm’s own written policies and procedures. 4. Misaligned Practices : Firms failed to identify or address discrepancies between their stated compliance policies and actual business practices, including unnoticed risk areas or unaddressed business changes. 5. Poor Documentation : Critical documentation related to annual reviews, including testing performed and corrective actions, was often incomplete or missing. 6. Unimplemented Corrective Actions : Identified issues and recommended changes from prior reviews were often not implemented, leading to persistent compliance weaknesses. Link to the Risk Alert here SEC Proposes Rescission of Political Contribution Rule for Investment Advisers On 3 September 2026, the SEC issued a proposal to rescind its “pay-to-play” rule that prohibits investment advisers from providing compensated investment advisory services to a government client for two years after making a political contribution to certain elected officials or candidates, and related recordkeeping requirements. The SEC says all other requirements of the Advisers Act and its associated rules, including prohibitions on fraud, fiduciary duty requirements, the compliance rule, and the code of ethics rule, would continue to apply. The SEC has determined that the political contribution rule, since its adoption in 2010, has led to significant unintended consequences, such as prohibitions by some advisers on political contributions at the state and local level. Advisers have indicated that the rule is operationally challenging to implement, and creates a de facto strict liability standard, which can lead to situations where small donations or “foot faults” potentially trigger substantial prohibitions and fines. Specifically, the proposal would rescind Advisers Act Rule 206(4)-5 and amend the Advisers Act recordkeeping rule to eliminate the corresponding provisions related to the political contribution rule.