Global Trustee and Fiduciary Services Bite-Sized Issue 4 2026

22 QUICK LINKS CMU CONDUCT CRYPTO ASSETS EMIR FINTECH FUND LIQUIDITY IOSCO OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 4 | 2026 CFTC Staff Issues Prediction Markets Advisory On 12March 2026, the Commodity Futures Trading Commission (CFTC) Division of Market Oversight (Division) issued a predictionmarkets advisory regarding the listing for trading of event contracts. In light of the rapid rise in popularity of prediction markets, the Division seeks to encourage growth and innovation in these markets while reminding designated contract markets of their regulatory obligations pursuant to the Commodity Exchange Act (CEA) and Commission regulations. The advisory, among other things, underscores the Divisions’ regulatory obligations with respect to CEA section 5(d) and Part 38, DCM Core Principle 3 and the Appendix C guidance, and product submission requirements. It also discusses certain nuances that may have particular applicability to sports-related event contracts. The Division believes that, as front-line regulators, designated contract markets should take proactive steps to ensure their markets continue to evolve in a manner that complies with the CEA and Commission regulations. Link to CFTC Staff Letter 26-08 here CFTC Seeks Public Comment on Advanced Notice of Proposed Rulemaking Relating to Prediction Markets On 12 March 2026, in addition to its advisory, the CFTC published an Advanced Notice of Proposed Rulemaking (ANPRM ), seeking public comment on the need to amend or issue new regulations concerning event contracts traded on prediction markets. The ANPRM asks questions concerning the application of statutory core principles and CFTC regulations to prediction markets, the types of event contracts that may be prohibited as contrary to the public interest, cost-benefit considerations related to prediction markets, and other topics. The CFTC intends to use the information and comments received to inform potential future agency action, such as a rulemaking, with respect to prediction markets. Comments must be in writing and received within 45 days of the ANPRM’s publication in the Federal Register. Link to 91 FR 12516 here SEC Releases FAQs on Fund of Fund Arrangements On 5 March 2026, the Securities and Exchange Commission (SEC) Division of Investment Management released new FAQs addressing the application of Rule 12d1-4, which governs fund of funds arrangements. The guidance provides clarity on when a fund of funds agreement is necessary between the acquiring and acquired funds. The FAQs also clarify that an acquired fund does not need to count investments in debt securities issued by collateralized loan obligations towards its 10% limitation. Advisers to funds of funds must review their compliance frameworks in light of this new staff guidance. Link to the FAQs here UNITED KINGDOM Joint FCA and ICO Statement on Regulatory Expectations Regarding Firms’ Approaches to Vulnerability Related Data On 27 March 2026, the Financial Conduct Authority (FCA) and the Information Commissioner’s Office (ICO) published a statement aimed at helping firms understand and apply the FCA’s expectations for delivering good outcomes for retail consumers in vulnerable circumstances, in line with the Consumer Duty, while also maintaining confidence in the lawful, fair and responsible use of personal information in line with the ICO’s expectations. The FCA requires regulated firms to act to deliver good outcomes for all consumers, including those in vulnerable circumstances. The FCA says that, in practice, this can involve processing personal information, and where appropriate, sharing data related to vulnerability.