Global Trustee and Fiduciary Services Bite-Sized Issue 7 2026

17 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 SEC says that the joint request for comment seeks input on a range of issues, including: • Existing portfolio margining models and practices; • Customer protection considerations; • Cross-margining and cross-product offsets; • Capital, segregation, and collateral treatment; • Risk management and margin methodologies; • Clearing agency and derivatives clearing organization considerations; • Operational and technical implementation issues; and • Potential impacts on market liquidity and competition. The public comment period will remain open for 60 days following publication of the request for comment in the Federal Register. Link to Joint Request for Comment here SEC and CFTC Seek Public Comment to Further Clarify and Harmonize Derivatives Product Definitions On 18 June 2026, the SEC and the CFTC issued a joint request for public comment on potential opportunities to further update, clarify, and harmonize certain derivatives product definitions and interpretive issues. The SEC says that the request for comment is intended to support its ongoing evaluation of whether current regulatory definitions, interpretations, and jurisdictional frameworks appropriately reflect evolving market structures, financial products, and trading practices. The joint request for comment seeks input on topics including: • Definitions relating to swaps and security-based swaps, including the scope of certain exclusions from the swap definition; • Treatment of mixed swaps; • Treatment of novel or emerging products; • Jurisdictional and interpretive questions; • Potential areas in need of greater clarity regarding regulatory definitional lines; and • Potential areas for alternative compliance. The public comment period will remain open for 60 days following publication of the request for comment in the Federal Register. Link to Joint Request for Comment here Examinations Observations of Investment Adviser Obligations Related to Economic Conflicts of Interest On 9 June 2026, the SEC’s Division of Examinations (the Division) issued a Risk Alert highlighting critical observations regarding investment adviser obligations concerning economic conflicts of interest, despite their fiduciary duty to eliminate or fully disclose such conflicts. The Division’s review of adviser activities identified economic conflicts of interest that were undisclosed, or the disclosures were incomplete or misleading. Additionally, the Division also observed adviser practices that were inconsistent with advisory agreements and disclosures. Finally, the Division says that staff observed compliance programs that did not fully address economic conflicts of interest and risks.