Global Trustee and Fiduciary Services Bite-Sized Issue 8 2026

19 AIFMD CRYPTOASSETS EMIR FINTECH IOSCO MIFID II/MIFIR OPERATIONAL RESILIENCE SUSTAINABLE FINANCE/ESG T+1 ASIA PACIFIC EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 8 | 2026 Quick Links SEC Proposes New E-Delivery Approach for Shareholder Disclosure Documents On 17 July 2026, the SEC proposed Regulation E-Delivery, a new rule that would expand the ability of issuers, broker-dealers, investment advisers, and others to use electronic delivery to satisfy information delivery requirements under the federal securities laws. The SEC states that Regulation E-Delivery would make information more readily accessible and useful for investors and others while preserving the ability to receive delivery in paper format on request. Currently, required regulatory information typically is delivered in paper format unless the recipient affirmatively elects otherwise. The proposed e-delivery approach includes requirements and conditions under which required information could be delivered electronically without first obtaining affirmative consent. It generally would supersede the SEC’s decades-old, guidance- based e-delivery approach and provide savings to issuers, market intermediaries, and, ultimately, investors, in paper, printing, and postage costs. According to the SEC, the proposal reflects how today’s issuers, market intermediaries, investors, and others use electronic media to provide and access information and E-delivery offers the opportunity to give investors and others potentially more personalized, interactive, timely, and efficient experiences with disclosure than paper delivery. It also provides accessibility and retention benefits. The range of information deliverable electronically under the proposed rule would be broad, including, among other things, prospectuses for funds and other issuers, fund annual and semi-annual shareholder reports, proxy statements, trade confirmations, disclosures pursuant to Form CRS, and Form ADV Part 2 Brochures. The proposal includes a transition process for investors and others who are currently receiving regulatory information in paper format. These recipients would receive two paper notices if they would be transitioned to e-delivery under the rule, which would provide information about the upcoming transition and the ability to opt out of e-delivery. Link to Proposed Rule here SEC Publishes Rulemaking Agenda On 7 July 2026, the SEC published its most recent Regulatory Agenda. On that same day, SEC Chair Paul S. Atkins delivered a statement on the Agenda. In his remarks Chair Atkins summarized his goals of returning the agency to its core mission of protecting investors, facilitating capital formation, and maintaining fair, orderly, and efficient markets. He stated that the SEC is embracing innovation to help establish the U.S. as the global crypto capital by bringing products onshore, clarifying capital raising rules and providing guidance on the on-chain custody and trading of tokenized securities. To revitalize public markets and increase IPOs, he explained that the Agenda includes proposals to transform the disclosure regime, focusing on materiality to reduce compliance burdens while maintaining investor protections. Finally, Chair Atkins emphasized the priority of safely expanding retail investor participation in private markets so that exposure to market dynamism is not reserved solely for wealthy insiders. Link to SEC Regulatory Agenda – 2026 here Link to Statement here UNITED KINGDOM Outcomes Monitoring: Good Practice and Areas for Improvement On 27 July 2026, the Financial Conduct Authority (FCA) published the findings of its review into firms’ approaches to monitoring consumer outcomes. The FCA says that, under the Consumer Duty, financial services firms must meet a high standard of retail consumer protection. A key part of this is monitoring whether their customers are getting good outcomes in practice. The FCA says this should help firms understand what is happening across the customer journey, identify poor outcomes or emerging risks, and take appropriate action. This applies across all 4 of the Consumer Duty outcomes: products and services, price and value, consumer understanding, and consumer support.

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