Global Trustee and Fiduciary Services Bite-Sized Issue 10 2026

21 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 9 November 2026 . Link to Rescission of Rule Related to Political Contributions by Certain Investment Advisers here Link to Fact Sheet here SEC Proposes to Modernize Rules for Registered Transfer Agents On 1 September 2026, the SEC proposed to update the rules and forms that apply to registered transfer agents. The SEC says that transfer agents are a key component of the national clearance and settlement system. Transfer agents now perform a more diverse array of functions and services that may not be adequately addressed by the SEC’s current transfer agent rules, which have not been substantively updated since the first rules were adopted in the late 1970s and early 1980s. The rule proposal would modernize the federal transfer agent rules, while continuing to facilitate the safe and efficient functioning of the U.S. securities markets and the national clearance and settlement system. The SEC says that the proposal would, among other things: • Amend the registration and annual reporting requirements for transfer agents, including the questions and instructions on Forms TA-1 and TA-2; • Modernize the rules to reflect how transfer agents carry out their activities in light of technological advancements, including the use of electronic and blockchain-based recordkeeping and uncertificated securities; • Establish new turnaround and posting requirements that align with modern shortened settlement cycles; • Reframe risk management rules to protect issuer and investor funds and securities; • Introduce new rules requiring written compliance policies and establishing clear procedures for placing and removing restrictive legends; and • Establish a single retention period for most transfer agent records and modernize the rule provisions governing use of electronic systems and third parties for recordkeeping. The public comment period will close on 3 November 2026 . Link to Fact Sheet here Link to Proposed rule: Transfer Agent Rules here UNITED KINGDOM FCA Publishes Handbook Notice No. 144 – Investment in cETNs On 25 September 2026, the Financial Conduct Authority (FCA) published Handbook Notice No. 144 which contains feedback on Chapter 5 of consultation paper CP26/17 on the holding of certain cryptoasset exchange traded notes (cETNs) by authorised funds. Following feedback to the consultation, the FCA has proceeded with its proposal to allow UCITS schemes and non-UCITS retail schemes to invest in cETNs up to a limit of 10% of the scheme property. This limit is sperate from the limit on investment in unapproved transferable securities. As a result of the feedback, the FCA has reversed its proposal to prevent funds of alternative investment funds (FAIFs) from investing in cETNs. As a result, FAIFs will also be permitted to invest up to 10% of their scheme property in cETNs. In addition, the FCA confirmed that cETNs held by authorised funds must comply with all rules relating to investment in transferable securities including those relating to embedded derivatives.