Global Trustee and Fiduciary Services Bite-Sized Issue 9 2026

12 AI CRYPTOASSETS EMIR FINTECH FUND LIQUIDITY OPERATIONAL RESILIENCE RETAIL INVESTMENT STRATEGY T+1 ASIA PACIFIC AUSTRALIA EUROPE NORTH AMERICA UNITED KINGDOM Global Trustee and Fiduciary Services Bite-Sized | Issue 9 | 2026 Quick Links NORTH AMERICA CFTC Further Extends Compliance Date for Amendments to Form PF On 31 August 2026, the Commodity Futures Trading Commission (CFTC) published a Joint Final Rule with the Securities and Exchange Commission (SEC), further extending the compliance date for the amendments to Form PF that were adopted on February 8, 2024 (“Form PF Amendments”), from 1 October 2026 to 1 July 2027. The CFTC explains that Form PF is the confidential reporting form for certain SEC-registered investment advisers to private funds, including those that also are registered with the CFTC as a commodity pool operator (a “CPO”) or a commodity trading adviser (a “CTA”). The CFTC says that extending the compliance date for the Form PF Amendments allows Form PF filers to avoid certain potentially significant costs associated with implementing the Form PF Amendments that the CFTC and SEC have subsequently proposed to amend and/or eliminate in a new rule proposal issued on 20 April 2026. The extension of the compliance date of the Form PF Amendments will provide the CFTC and SEC time to fully consider comments received on the April 2026 rule proposal. Link to Federal Register here CFTC Seeks Public Comment on Proposed Rule Changes for Commodity Pool Operator and Commodity Trading Advisor Registration On 18 August 2026, the CFTC published a Notice of Proposed Rulemaking seeking public comments on amendments to part 4 of the CFTC’s regulations. The CFTC says that these amendments address registration requirements for commodity pool operators and commodity trading advisors, and the proposed rule aims to reduce duplicative and overlapping regulation. The CFTC says that the proposed rule specifically would: • Add an exemption from Commodity Pool Operator (CPO) registration for certain investment advisers registered with the SEC in relation to commodity pools for which the participants are limited to certain sophisticated investors and which meet other conditions discussed in the proposal; • Add a related registration exemption for Commodity Trading Advisors; and • Increase the capital contribution threshold in the current CPO registration exemption for small commodity pools, also known as the small pool exemption, to reflect inflation. Comments will be accepted for 45 days following publication in the Federal Register. Link to Federal Register here UNITED KINGDOM FCA Publishes Review of High-growth Firms: Good and Poor Practice On 10 August 2026, the Financial Conduct Authority (FCA) published a review of good practice and areas for improvement identified through its Early and High Growth Oversight pilot with high- growth firms. The FCA explains that, between July 2025 and March 2026, it engaged with 15 firms across asset management, wealth management and payments as part of a high-growth pilot. The FCA says that this was to identify rapidly growing firms earlier and support them as they establish and evolve their business. The FCA assessed whether their governance, risk management and control frameworks were developing in line with their growth. For the authorised firms captured, the FCA says the review will be of interest to firms’ boards, individuals in senior management functions and those responsible for risk, compliance and operational oversight.