Global Trustee and Fiduciary Services Bite-Sized Issue 6 2026

21 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 The divisions’ no-action position covers all beneficiaries of previous no-action letters concerning data reporting for similar contracts. Entities wishing to list or clear similar contracts may request a no-action position identical to the letter. If the divisions grant such a request, they will add the requester to the appendix to the no-action letter. This approach removes the need for the divisions to continually issue identical no-action letters and ensures consistent treatment for new and previous applicants. Link to the CFTC Staff Letter here CFTC Issues Proposed Rule to Modify Clearing Requirement for Canadian Dollar- and Mexican Peso-Denominated Interest Rate Swaps On 8 May 2026, the CFTC issued a proposal to update its swap clearing requirements under CFTC Regulation 50. The change would remove the obligation to clear certain Canadian dollar (CAD) and Mexican peso (MXN) interest rate swaps that reference the Canadian Dollar Offered Rate (CDOR) and the Interbank Equilibrium Interest Rate (TIIE) and replace themwith a requirement to clear swaps referencing overnight, nearly risk-free rates. Key Changes in the Proposal • CAD swaps: – Move from the fixed-to-floating swap class to the overnight index swap (OIS) class. – Expand the stated termination date range for OIS-class CAD swaps referencing the Canadian Overnight Repo Rate Average (CORRA) from 7 days to 30 years. • MXN swaps: – Add to the OIS class swaps referencing the Overnight TIIE Funding Rate with a termination date range of 28 days to 21 years. • Removals: – Remove CAD swaps referencing CDOR from the fixed-to-floating swap class. – Remove MXN swaps referencing TIIE from the fixed-to-floating swap class. Link to Federal Register here Proposed Rule Change to Update Fund/SERV System On 1 May 2026, the National Securities Clearing Corporation (NSCC) filed with the SEC a proposed rule change, which consists of amendments to the NSCC rules to: i. Update Fund/SERV® to facilitate the exchange of a mutual fund share to an exchange-traded fund (ETF) share class; ii. Shorten the settlement time for certain Networking Payments to the same day NSCC is notified of the payment; and iii. Clarify the Fund/SERV transaction fees charged to NSCC Members. Link to the Proposed Rule Change here UNITED KINGDOM Registration of Authorised Fund Assets On 21 May 2026, the Financial Conduct Authority (FCA) launched a consultation on the registration of authorised fund assets (CP26/16). The FCA says it has issued this consultation as it wants to make sure UK authorised alternative investment funds (authorised AIFs) can continue to invest in private markets, while still protecting the fund investors. The proposed rule changes would: • Have the effect of allowing depositaries of authorised AIFs managed by Authorised FundManagers (AFMs) that are also defined as ‘full-scope’ AIFmanagers (AIFMs) to delegate some of their safekeeping functions in respect of some private markets asset types to certain third parties;