Global Trustee and Fiduciary Services Bite-Sized Issue 9, September 2026

中文标题

全球受托人与信托服务快讯第9,期 2026年9月

Citi09/09/2026updated 10/17/2026

Citable research brief

Core conclusion · Tlines extraction

Citi's regulatory update covers a proposed SEC framework for crypto asset offerings with two registration exemptions (up to $5m over four years, or $75m per 12 months), a conditional safe harbor from investment contract status and a 60-day comment period. The FCA finalised fund liquidity risk management rules effective 1 Feb 2027, with transitional provisions to 1 Aug 2027, and published a T+1 readiness blog ahead of an October 2027 live date. MAS announced measures to strengthen asset management; ASIC set out its 2026-27 corporate plan; the Commission asked ESMA for technical advice on the Retail Investment Strategy by 1 Oct 2027.

Institution: Citi
Published: 09/09/2026
Research topic: Not explicitly stated
Time horizon: 2026 · October 2027

Key arguments

The SEC proposed "Regulation Crypto Assets" on 18 August, building on March interpretive guidance, with two new Securities Act registration exemptions and a conditional safe harbor from investment contract status.
The FCA finalised fund liquidity risk management rules in PS26/17, promoting anti-dilution tools and covering UCITS and non-UCITS retail schemes, effective 1 February 2027.
MAS announced three measures—a tax exemption for fund management profit-related returns, a hedge fund investment programme and an Investment Management Track—to strengthen Singapore's asset management hub.
The European Commission requested ESMA technical advice on implementing Retail Investment Strategy amendments across MiFID II, UCITS and AIFMD by 1 October 2027.

Key numbers

SEC first exemption offering cap: USD 5 million over a four-year period
SEC second exemption offering cap: USD 75 million per 12-month period
SEC comment period: 60 days once published in the Federal Register
FCA liquidity rules effective date: 1 February 2027, transitional provisions to 1 August 2027
Singapore asset management industry size: almost SGD 7 trillion, growing 7.5% per year on average over five years

Main risks

The SEC's crypto proposals remain subject to a 60-day comment period and could change before finalisation.
The FCA's T+1 transition presents operational risks for firms; the FCA's blog notes expectations with one year to go, including trade date allocations, confirmations and standard settlement instructions.
ASIC is increasing focus on AI, including how banks use AI in customer-facing services and how AI-driven manipulation, deepfakes and misinformation could undermine market integrity.

Corresponding source evidence

The blog sets out the FCA’s reflections from their engagement, including on where the FCA expects firms to be with 1 year to go and progress on 2026 recommendations: for example, trade date allocations and confirmations, and standard settlement instructions. · 2026
Matt: Released on 26th of August, it covers 2026-27 and sets out how ASIC will be easier to deal with for businesses trying to comply with the law, and harder to avoid for those causing harm. · 2026
4 Alongside that, it is committing to cutting unnecessary regulatory burden through simpler guidance, better digital services, more efficient licensing processes and closer coordination with other regulators on data collection.

Context: the conclusion is Tlines' automated extraction, not the institution's wording. Quoted evidence is publisher wording. Scope and date must travel with the conclusion.

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