Global Trustee and Fiduciary Services Bite-Sized Issue 7 2026

18 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 Areas of Observation: • Conflicts of Interest Associated with Advisers’ Cash Management Recommendations – Disclosures related to revenue sharing arrangements. – Disclosures related to fees, expenses, and conflicts of interest. – Disclosures related to money market fund share class selection. • Conflicts of Interest Associated with Other Revenue Opportunities – Disclosures related to mutual fund share class selection. – Disclosures regarding other economic benefits. • Disclosing Fees and Economic Conflicts of Interest in Form ADV – Disclosures under Item 10 of the brochure. – Disclosures under Item 12 of the brochure. • Fees Deviating from Advisory Agreements and Fee-Related Disclosures – Calculating fees consistent with advisory agreements and disclosures. – Calculating fees consistent with services actually provided. – Refunding unearned fees. • Compliance Programs Identifying and Addressing Fee-Related Issues – Addressing all types of billing arrangements. – Describing advisory fee-related practices clearly and consistently. – Monitoring for accurate fee-billing. In its conclusion, the Division says that its staff continue to observe compliance issues when advisers have economic conflicts of interest with their clients. The Division says that it encourages advisers to review and refine, as appropriate, their billing policies, procedures, and practices on a routine basis with an eye towards ensuring they are accurate and consistent with disclosures and agreements. Additionally, it says that advisers should also identify and address timely new conflicts of interest. Lastly, the Division says in the Risk Alert that advisers are encouraged to review their disclosures regarding their economic conflicts of interest to ensure that clients are provided with full and fair disclosure. Link to Risk Alert here SEC Publishes Draft Strategic Plan (FY26-FY30) On 2 June 2026, the SEC released a Draft Strategic Plan for public comment, outlining goals for 2026-2030, focusing on protecting investors, maintaining fair markets, and facilitating capital formation. The three Goals set forth in the Draft Strategic Plan are: 1. Renew the SEC’s regulatory policy focus to support innovation, capital formation, market efficiency, and investor protection . The SEC says that this goal promotes clear, fit-for-purpose rules that foster responsible innovation and deter misconduct. The SEC also says that one objective is to provide a firm regulatory foundation for digital assets and distributed ledger technologies through a rational, coherent, and principled approach.