Global Trustee and Fiduciary Services Bite-Sized Issue 6 2026

20 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 • More public companies would be able to utilize certain registration and offering communication flexibilities that currently are reserved for companies with a large public float defined as “well-known seasoned issuers.” • Broker-dealers would be able to provide research report coverage for a greater number of public companies. • State securities law registration and qualification requirements would be pre-empted for all registered offerings, which would mitigate the costs and complexity of conducting a multi-state registered offering. • Parity between certain FormN-2 filers and operating companies across registration, offering, and communication provisions would be maintained, and access to broad-based advertising for certain non-variable annuity insurance products would be expanded. • Other aspects of the registration process would be streamlined, such as the ability to incorporate information by reference into Form S-1. Link to the Proposed Rule here FINRA Announces Publication of Interpretations and Investor Education Materials Relating to New Intraday Margin Standards On 19 May 2026, FINRA published updated interpretations of its margin rule (FINRA Rule 4210) to provide guidance to members in implementing the new intraday margin standards. Correspondingly, FINRA is deleting all interpretations relating to the former day trading margin requirements, which the new intraday margin standards have replaced in their entirety. Also, FINRA has made available educational resources, which members can share with customers, that provide information about the new intraday margin standards and margin accounts. The new and modified interpretations are available at Interpretations of Rule 4210. The new educational resources are available at: X Investor Insights: Understanding the NewMargin Requirements X Brokerage Accounts: Margin Account. Link to Regulatory Notice 26-11 here CFTC Staff Issues Advisory on Cooperation in Enforcement Matters On 19 May 2026, the Commodity Futures Trading Commission (CFTC) issued a staff advisory containing the Division of Enforcement’s new policy on cooperation. The CFTC says that, absent aggravating circumstances, the advisory lays out a path for a potential declination when a respondent voluntarily self-reports, fully cooperates, effects timely and appropriate remediation, and provides full restitution and/or disgorgement. Additionally, the advisory details what level of cooperation credit may be awarded to respondents for self-reporting and cooperation when they are ineligible for a declination. Link to the Staff Advisory here CFTC Staff Issues No-Action Letter on Data Reporting for Event Contracts On 13May 2026, the CFTC’s Division of Market Oversight andDivision of Clearing and Risk announced they have taken a no-action position regarding swap data reporting and recordkeeping regulations. The divisions will not recommend the CFTC initiate an enforcement action against designated contract markets, derivatives clearing organizations, or their participants for failure to comply with certain swap-related recordkeeping requirements and for failure to report to swap data repositories data associated with fully collateralized event contract transactions. This no-action position is subject to the terms of the no-action letter. The CFTC says this position is in response to numerous requests from designated contract markets (DCMs) and derivatives clearing organizations (DCOs) that list and clear event contracts. The divisions anticipate receiving similar requests, including requests to modify previous no- action positions to account for amendments to DCM designation orders, changes in DCOs, and other developments. The divisions intend for the no-action position to streamline the process for addressing such requests and to ensure uniform treatment of market participants.