Global Trustee and Fiduciary Services Bite-Sized Issue 7 2026

16 AI CRYPTOASSETS CYBER DORA IOSCO MONEY MARKET FUNDS SUSTAINABLE FINANCE/ESG ASIA PACIFIC AUSTRALIA EUROPE IRELAND LUXEMBOURG NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 7 | 2026 Quick Links The CSSF adds that it launched at the end of 2023, by means of a dedicated questionnaire, an ad hoc thematic review (“Thematic Review”) with work carried out throughout 2024 and 2025 and focused primarily on valuation practices of AIFMs managing AIFs investing in less liquid/illiquid assets (e.g. private equity, real estate, infrastructure, private debt or fund of funds). On an ancillary basis, the review also dealt with valuation aspects/risks related to investments of UCITS under Article 41(2) of the UCI Law (i.e. the so-called “trash ratio” investments), notably unlisted securities or listed securities that are not actively traded. The CSSF says that the Thematic Review scrutinised more particularly some specific aspects/ areas of the valuation policies and procedures of Investment Fund Managers (IFMs) as well as the valuation controls in place during the life cycle of the investments. The CSSF explains that the objective of its communique is to informmarket participants about the publication of the CSSF Feedback Report “Thematic review – Valuation framework for less liquid and illiquid assets”. It says that the Feedback Report provides IFMs, based on the applicable regulation, with guidance in relation to the implementation andmaintenance of robust and appropriate valuation policies and procedures as well as valuation controls for the AIFs/UCITS they manage. Also, the CSSF says that it sets out, more particularly, a number of observations/recommendations which aim at harmonising and enhancing valuation practices of IFMs in certain areas. The CSSF says that all IFMs are expected to carry out a benchmarking exercise against these observations/ recommendations and, if applicable, to proceed in a next step to the necessary corrective measures. Finally, considering the growth of AIFs investing in less liquid and illiquid assets, the increasing participation of retail investors in these funds, but also the current geopolitical uncertainties, the CSSF says that valuation risk remains a key supervisory priority of the CSSF in 2026. Link to CSSF Feedback Report here NORTH AMERICA SEC Seeks Public Comment on Novel Exchange-Traded Funds On 30 June 2026, the Securities and Exchange Commission (SEC) issued a request for public comment on exchange-traded funds (ETFs) seeking to invest in innovative asset classes or engage in novel investment strategies. The SEC says that the request focuses on ways to facilitate innovation in the ETF space while protecting investors, maintaining fair, orderly, and efficient markets, and facilitating capital formation. The SEC says that it encourages feedback on the important questions raised in its release. The SEC requests comment with respect to: • The status of certain novel ETFs as investment companies; • The regulation of novel ETFs; and • How the registration process for novel ETFs can continue to operate effectively. The public comment period will remain open for 60 days following publication of the request for comment in the Federal Register. Link to Request for Comment on Novel ETFs here SEC and CFTC Seek Public Comment on the Harmonization of Portfolio Margining Frameworks On 26 June 2026, the SEC and the Commodity Futures Trading Commission (CFTC) issued a joint request for public comment on potential approaches to further harmonize regulatory frameworks applicable to portfolio margining across securities, security-based swaps, futures, swaps, and related positions. In its press release, the SEC says that the request for comment is intended to assist the agencies in evaluating whether greater coordination or alignment in portfoliomargining requirements may improve risk management efficiency, reduce unnecessary market fragmentation, and enhance customer protections consistent with the agencies’ respective statutory authorities and responsibilities.