Global Trustee and Fiduciary Services Bite-Sized Issue 2 2026

17 QUICK LINKS AIFMD BENCHMARKS REGULATION CRYPTOASSETS FINTECH FUND LIQUIDITY MIFID II/MIFIR MONEY MARKET FUNDS OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 2 | 2026 Statement on Reforming Regulation S-K On 13 January 2026, SEC Chairman Paul S. Atkins issued a statement on reforming Regulation S-K. In his Statement, Chairman Atkins said the aimof the is initiative to conduct a comprehensive review of Regulation S-K, which governs non-financial disclosure requirements for filers since 1982. The core issue is that Regulation S-K has evolved to elicit an overwhelming amount of information, much of which is deemed immaterial, thus hindering investors’ ability to discern critical data for investment and voting decisions. Chairman Atkins said the SEC aims to revise these requirements to focus solely onmaterial information, thereby protecting investors and facilitating capital formation. To address these challenges, the Division of Corporation Finance has been instructed to undertake a comprehensive review of Regulation S-K. The initial step of this review commenced in May 2025. The SEC sought public comments and held a roundtable discussion specifically on the executive compensation disclosure requirements, which are detailed in Item 402 of Regulation S-K. This phase has garnered significant public engagement, with over 70 unique comment letters received. Chairman Atkins said the SEC staff is currently in the process of evaluating these submissions and formulating recommendations for potential revisions to Item 402 for the SEC’s consideration. Following the review of Item 402, the SEC staff will shift its focus to the remaining requirements of Regulation S-K. Chaiman Atkins said the SEC actively encourages public participation and invites stakeholders to submit their views on how Regulation S-K can be amended. The primary goal for these amendments is to refine the requirements to ensure that only material information is elicited, effectively eliminating the need to disclose immaterial information. The closing date for comments is 13 April 2026. Link to Statement here SEC Publishes List of Rules to be Reviewed Pursuant to the Regulatory Flexibility Act and Requests Comments On 7 January 2026, the SEC published a list of rules to be reviewed under the Regulatory Flexibility Act. The list provided the public with notice that these rules are scheduled for review by the SEC and invited comment, by 11 February 2026, on whether the rules should be continued without change, or should be amended or rescinded to minimize any significant economic impact of the rules upon a substantial number of small entities. The areas of review include: • Form ADV and Investment Advisers Act Rules; • Investment Company Reporting Modernization; • Investment Company Swing Pricing; and • Investment Company Liquidity Risk Management Programs. Link to the Federal Register here SEC Proposes Amendments to the Small Entity Definitions for Investment Companies and Investment Advisers for Purposes of the Regulatory Flexibility Act On 7 January 2026, the SEC proposed amendments to the rules that define which registered investment companies, investment advisers, and business development companies qualify as small entities for purposes of the Regulatory Flexibility Act (RFA). The RFA requires federal agencies to conduct certain analyses, with the goal of minimizing the significant economic impact of federal rulemaking on small entities. This proposal would raise the small entity thresholds for investment companies and advisers. It is designed to help the SEC better tailor its analyses to address the specific regulatory challenges that these small entities face and consider adapting its rulemaking accordingly.