Global Trustee and Fiduciary Services Bite-Sized Issue 5 2026

16 QUICK LINKS AI CRYPTOASSETS CYBER EMIR FINTECH FUND LIQUIDITY MICA SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE IRELAND NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 5 | 2026 The proposing release for the amendments will be published in the Federal Register, and the public comment period will remain open until 60 days after publication in the Federal Register. Link to SEC Fact Sheet on Proposed Amendments to Form PF here Link to Joint Proposed Rules here SEC Approves Exemptive Order and Proposed Rule Change to Permit Customer Cross- Margining in the U.S. Treasury Market On 15 April 2026, the SEC issued a conditional exemptive order that permits customer cross- margining of cash market positions in U.S. Treasury securities cleared by a registered clearing agency and futures positions in U.S. Treasury securities cleared by a registered derivatives clearing organization. The SEC’s order provides for an exemption from the broker-dealer customer protection rule for a broker-dealer that is dually-registered as a futures commission merchant with the CFTC, and is a joint clearing member of the clearing agency and derivatives clearing organization, to permit the broker-dealer to make cross-margining available to certain customers in a futures account provided the conditions of the order are met. Link to SEC Exemptive Order here SEC Announces Enforcement Results for Fiscal Year 2025 On 7 April 2026, the SEC released its enforcement results for the 2025 fiscal year. The results reflect the SEC’s focus on protecting retail investors, who may be particularly vulnerable to securities fraud, holding individual wrongdoers accountable, combatting securities fraud wherever it occurs, as well as safeguarding markets from abusive trading. The SEC highlighted in its release that enforcement priorities and results will be linked to the SEC’s core mandate, and will contemplate the following elements to fulfill its mission: Standing up to fraud in its many forms and those market participants engaged in such misconduct; addressing the fraudulent and manipulative conduct of the parties in question through appropriate remediation; and repaying investors’ losses when harmed. In its release, the SEC also noted that it made a necessary course correction in its approach to enforcing the federal securities laws in the context of crypto assets. The SEC remains says that it is committed to detecting, deterring, and bringing actions against those seeking to take advantage of investors by misusing new technologies. In February 2025, the SEC announced the launch of the Cyber and Emerging Technologies Unit to complement the work of the Crypto Task Force and to protect investors by combatting misconduct as it relates to securities transactions involving blockchain technology, AI, account takeovers, cybersecurity, and other areas. Link to SEC Press Release here Link to Addendum here UNITED KINGDOM FCA Consults on Changes to IPO Research Rules On 27 April 2026, the Financial Conduct Authority (FCA) published ‘Consultation Paper CP26/14 – Changes to information flows for UK equity IPOs’. The FCA says that it is consulting on removing the requirement for a 7-day delay before connected research on an IPO can be published. The FCA adds that it is also consulting on removing rules that require firms to provide independent analysts with the same information as their own research analysts. The FCA explains that these rules were introduced in 2018 to encourage the production of unconnected research, but they have not achieved that aim. However, feedback from the market suggests that they have also added complexity, risk and cost to the IPO process, and have put the UK at a competitive disadvantage compared with other international listing venues.