Global Trustee and Fiduciary Services Bite-Sized Issue 6 2026

19 AIFMD CRYPTOASSETS FINTECH FSB IOSCO MIFID II/MIFIR MONEY MARKET FUNDS OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 6 | 2026 Quick LInks NORTH AMERICA SEC and NFA Announce Memorandum of Understanding to Further Harmonize Regulatory Coordination On 21 May 2026, the Securities and Exchange Commission (SEC) and National Futures Association (NFA) announced that they have entered into a Memorandum of Understanding (MoU) to enhance their cooperation, coordination, and information sharing in areas of common regulatory interest. The MOU will enhance SEC and NFA staff ’s ability to share information on matters of mutual regulatory interest such as emerging risks, examination planning, and financial markets’ conditions. The MOU will also provide for periodic meetings between staff. This improved coordination will further enhance the SEC and NFA’s ability to promote compliance with derivatives and securities laws, maintain the highest level of oversight quality, and minimize duplicative efforts. Link to the MoU here FINRA Announces Review of Higher-Risk Structured Products On 19 May 2026, the Financial Industry Regulatory Authority (FINRA) announced that it will review firm practices regarding higher-risk structured products, specifically non-principal protected “worst-of ” structured notes. The review will examine how firms supervise concentrations in these products, including how they comply with Regulation Best Interest and FINRA rules when their registered representatives recommend these products to investors. FINRA says it has identified multiple instances where firm representatives have concentrated their customers’ assets in structured products that increase complexity and risk. This includes characteristics such as a lack of principal protection and “worst-of ” features, among others. FINRA says that highly concentrated investments can pose risk, and that risk is heightened when the concentrated investment is a complex product. Structured notes can expose investors to losses not correlated with overall market conditions. Some investors have lost significant portions of their portfolios through such concentrated positions. FINRA says its review of firm supervision for concentration in higher-risk structured products will only affect a subset of member firms. However, it encourages all firms that recommend these products to review the questions in the letter and evaluate their practices. This includes firms’ training, guidance, controls and supervisory structure for professionals making these product recommendations to clients. Link to the ReviewDetails here SEC Proposes Transformative Reforms to Help Public Companies Conduct Registered Offerings and Simplify Reporting Requirements On 19 May 2026, the SEC proposed amendments to its rules and forms governing registered offerings that are designed to increase efficiency, flexibility, and cost savings for public companies while maintaining robust investor protections. The SEC also proposed rule amendments to simplify its public company reporting framework and better calibrate disclosure obligations with a company’s size and maturity. The United States’ dynamic public securities markets offer benefits to issuers and investors alike. Issuers can raise capital through the public markets on more favourable terms as compared to private markets, and investors benefit from the increased transparency and liquidity provided by the public markets. The SEC says that compounding regulatory requirements over recent decades have corresponded with a decrease in the number of public companies. The proposed amendments – together with the recently proposed optionality for semi-annual interim reporting and other forthcoming rule proposals – represent important steps toward incentivizing companies to go and stay public. The SEC says the registered offering reform proposal, if adopted, would be the most significant modernization of the registered offering framework in more than 20 years. Under the proposal: • A greater number of public companies would be able to conduct shelf offerings, which allow quicker access to the public capital markets, regardless of the company’s public float.