Capital Markets & Trading

What Changed

The primary regulatory modification addresses a single-day exception to standard options exercise procedures: CEA Cut-Off Time Acceleration: The normal 5:30 p.m. ET deadline for submitting Contrary Exercise Advice was compressed to 10:00 a.m. ET on January 9, 2025. Exercise Instruction Acceptance Window: Members could not accept exercise instructions for either customer or non-customer accounts after 10:00 a.m. ET on that date. OCC Processing Unchanged: The Options Clearing Corporation's proc

What You Need To Do

• *Update Internal Procedures
• *System Configuration
• *Staff Communication
• *Customer Notification
• *Submission Coordination

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

The Section 31 fee rate drops from $27.80 per million dollars to $0.00 per million dollars for covered securities transactions on exchanges and over-the-counter markets, applicable to trade dates (charge dates) of May 14, 2025, or later.[https://www.finra.org/rules-guidance/notices/information-notice-20250424] The assessment on security futures transactions remains unchanged at $0.0042 per round turn transaction.[https://www.finra.org/rules-guidance/notices/information-notice-20250424] FINRA wil

What You Need To Do

• Update internal billing, invoicing, and financial reporting systems to reflect the $0
• Review and adjust any automated fee calculations or client pass-through mechanisms for transactions on or after the effective date
• Contact FINRA's Amanda Rath for finance questions ((240) 386-6637) or SEC's Robert McNamee/Faisal Sheikh for legal/interpretive issues; monitor SEC website for updates
• Test systems for security futures (unchanged rate) and confirm no inadvertent charging of Section 31 fees post-effective date

Key Dates

References

• [1] ez-xbrl.com
• [2] cooleypubco.com
• [3] sec.gov
• [4] finra.org
• [5] nelsonmullins.com
• [6] infomemo.theocc.com
• [7] sec.gov
• [8] federalregister.gov

What Changed

Termination of Fee 2025-1: No longer applied to transactions after June 30, 2025, per FINRA Rule 6897(b)(1)(D), which requires notice upon replacement by a subsequent fee. Implementation of Fee 2025-2: New fee recovers FINRA's ~$7.27 million share of budgeted CAT costs for July 1–December 31, 2025; monthly invoicing begins for July 2025 transactions. Distinction from CAT LLC fees: Unrelated to "CAT Fee 2025-1" (assessed by CAT LLC, rate $0.000022 per transaction, remains in effect). #

What You Need To Do

• Verify internal systems stop applying Fee 2025-1 post-June 30, 2025, and prepare for Fee 2025-2 invoicing starting July transactions
• Review and pay final Fee 2025-1 invoice (due August 2025) per Rule 6897(b)(2)
• Update budgeting/forecasting models for Fee 2025-2 (covers H2 2025 CAT costs); monitor FINRA notices for rate details via SR-FINRA-2025-010
• Contact Amanda Rath ((240) 386-6637) or Faisal Sheikh ((202) 728-8379) for questions
• Distinguish FINRA fees from CAT LLC fees to avoid double-counting in financial controls

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] federalregister.gov
• [4] sec.gov
• [5] finra.org
• [6] findknowdo.com
• [7] catnmsplan.com
• [8] compliance-risk.com

What Changed

Effective January 1, 2023, amendments to FINRA Rule 1240 mandate annual completion of both Regulatory Element and Firm Element for all registered persons, per CE Council recommendations.[https://www.finra.org/rules-guidance/notices/information-notice-20250814] Launched July 1, 2024, the Financial Learning Experience (FLEX) serves as an optional centralized catalog for Firm Element e-learning courses to support written training plans.[https://www.finra.org/rules-guidance/notices/information-notic

What You Need To Do

• Registered persons
• Verify FinPro access/recovery; contact FINRA Testing and Continuing Education Department for questions

Key Dates

References

• [1] stcusa.com
• [2] nasaa.org
• [3] finra.org
• [4] questce.com
• [5] finra.org
• [6] finra.org

What Changed

Removal of Settle Prep Day: NSCC Rule 50 amended to eliminate the settlement preparation stage from ACATS, effective October 17, 2025, streamlining the process for all securities transfers.[original notice] Mutual Fund/Options Synchronization: Eliminates the extra day for processing mutual funds and options via Fund/SERV, aligning their settlement with other assets; also removes the second day of Fund/SERV pending acknowledgment.[original notice] Overall Timeline Reduction: Full ACATS transfers

What You Need To Do

• Operational Readiness
• Exception Handling
• System Updates
• Contact FINRA/NSCC

Key Dates

References

• [1] ftfnews.com
• [2] finra.org
• [3] advisorfinder.com
• [4] finra.org
• [5] sec.gov
• [6] finra.org
• [7] finra.org
• [8] sec.gov

What Changed

No new regulatory requirements or rule amendments; this is guidance providing a pre-calculated Filing Schedule for 2026 to prevent errors in the REX system. It emphasizes using schedule dates around holidays when exchanges or banks close, and confirms fixed SEA Rule 15c3-3 deadlines (e.g., 30th/45th calendar days post-settlement, 10th business day for (m) possession/control, regardless of foreign settlement cycles). #

What You Need To Do

• Access and reference the 2026 Filing Schedule on FINRA's website (via https://www
• Input schedule-specific dates for extensions, particularly around 2026 holidays when exchanges/banks close, to avoid automatic denials
• File SEA Rule 15c3-3 extensions on exact due dates listed above, even for foreign-traded securities
• Contact Theresa Reynolds (646-315-8567 or email) for questions
• Update internal compliance calendars, training, and systems to integrate the schedule

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] finra.org
• [7] finra.org
• [8] federalregister.gov

What Changed

Electronic Filing Mandates: All specified filings must be submitted electronically via FINRA Gateway; SEC no longer accepts paper Annual Reports, requiring EDGAR PDF submissions under amended SEA Rule 17a-5(d)(6)(i). https://www.finra.org/rules-guidance/notices/information-notice-20251110 SEC Interactive Data Compliance Dates: Annual reports and supplements must be filed as Interactive Data Files per Rule 405 of Regulation S-T; firms with net capital ≥$250,000 (as of Dec 31, 2025) comply for fi

What You Need To Do

• Submit all filings electronically via FINRA Gateway by 11:59 p
• For 30-day extension
• Affirm de minimis exemptions in eFOCUS for OBS/SIS/SLS where applicable
• Prepare for Interactive Data
• Contact firm's Risk Monitoring Analyst for questions; review eFOCUS guidance and SIPC site

Key Dates

References

• [1] finra.org
• [2] finra.org
• [3] finra.org
• [4] finra.org
• [5] finra.org
• [6] ria-compliance-consultants.com
• [7] fairviewinvest.com
• [8] thinkadvisor.com

What Changed

Electronic Filing Mandate: SEC no longer accepts paper submissions of annual reports (Form X-17A-5 Part III), supplemental reports under SEA Rule 17a-5(k), and Form 17-H; all must be filed on EDGAR in PDF format.[https://www.finra.org/rules-guidance/notices/information-notice-20251114] Electronic Signatures Permitted: Allowed for all SEA Rule 17a-5 reports (including annual and FOCUS Reports) via specified processes, e.g., Adobe Acrobat digitally signed certificates with document locking; FOCUS

What You Need To Do

• Implement electronic signature processes (e
• Retain signed Oath or Affirmation for 6 years per SEA Rule 17a-4 (no notarization)
• Review FINRA eFOCUS page for FOCUS amendments; prepare for interactive data filings per net capital tier (test systems in advance)
• Direct questions to firm's Risk Monitoring Analyst

Key Dates

References

• [1] quadrantregulatory.com
• [2] finra.org
• [3] pkfod.com
• [4] finra.org
• [5] quadrantregulatory.com
• [6] finra.org
• [7] capmktsreg.org

What Changed

National options exchanges will close at 1:00 p.m. ET on November 28, 2025, triggering a modified exercise cut-off under FINRA Rule 2360(b)(23)(A)(viii): deadline is 1 hour 30 minutes after close (i.e., 2:30 p.m. ET), overriding the standard 5:30 p.m. ET. Firms may set earlier internal deadlines for accepting exercise instructions but cannot accept any after 2:30 p.m. ET per FINRA Rule 2360(b)(23)(A)(vi). Reiterates standard procedures: in-the-money options auto-exercise under OCC Rule 805 (Exer

What You Need To Do

• Update client communications
• Configure systems and procedures
• Train staff
• Monitor and record
• Contact FINRA contacts (James Turnbull or Matthew Vitek) for clarification

Key Dates

References

• [1] finra.org
• [2] davispolk.com
• [3] finra.org
• [4] gtlaw.com
• [5] mayerbrown.com
• [6] finra.org
• [7] sec.gov
• [8] carltonfields.com

What Changed

Amendments to five technical notes: FCA/TN/506.2 (Periodic financial information and inside information), Primary Market/TN/507.1 (Structured digital reporting for IFRS annual statements, reflecting new ESEF taxonomy per DTR 4.1.15R), UKLA/TN/520.2 (Delaying disclosure/dealing with leaks and rumours), UKLA/TN/521.3 (Assessing and handling inside information), and UKLA/TN/542.2 (Issuer's obligations on position disclosures). Broader PMB 55 finalises 44 notes (e.g., TN/209.4 on Listing Principle 2

What You Need To Do

• Review blacklined amendments in GC25/1 and PMB 55; submit feedback by 15 May 2025 if impacted
• Update internal policies, training, and procedures to reflect finalised notes (e
• Until finalised, interpret existing guidance in light of UKLR; monitor for TN/710 update in future PMB
• For digital reporting, prepare for new ESEF taxonomy in annual IFRS statements

Key Dates

References

• [1] regulationtomorrow.com
• [2] jdsupra.com
• [3] fca.org.uk
• [4] hsfkramer.com
• [5] fca.org.uk
• [6] equiniti.com
• [7] lexisnexis.co.uk
• [8] linklaters.com

What Changed

Amendments to TN 710.1 (Sponsor Services: Principles for Sponsors): Revisions clarify the scope of 'preparatory work' and sponsor obligations under UKLR 4, building on feedback from PMB 48, 53, and PS24/6; changes marked against PMB 53 version. New TN 638.1 (Guidance on complex financial history and significant financial commitment rules): Updated draft provides detailed guidance for prospectus applications by companies with complex histories (e.g., acquisitive models), including scenarios, exam

What You Need To Do

• Review and respond
• Update policies/processes
• Monitor finalisation
• Implement NSM changes

Key Dates

References

• [1] jdsupra.com
• [2] fca.org.uk
• [3] fca.org.uk
• [4] fca.org.uk
• [5] ukfinance.org.uk
• [6] hoganlovells.com
• [7] lexisnexis.co.uk
• [8] hsfkramer.com

What Changed

CTP Obligations: Proposed rules establish core regulatory requirements for CTPs, including governance, operational resiliency, data collation/distribution, competitive pricing, and simple licensing structures to ensure accessibility and affordability. Data Contributor Obligations: Trading venues and Approved Publication Arrangements (APAs) must provide trade data (e.g., prices, volumes) to the CTP, covering trades across venues and OTC equity transactions. Scope and Outcomes: CT focuses on post-

What You Need To Do

• Respond to Consultation
• Data Readiness
• Monitor Updates
• Engage Stakeholders
• Compliance Mapping

Key Dates

References

• [1] fca.org.uk
• [2] jdsupra.com
• [3] ashurst.com
• [4] regulationtomorrow.com
• [5] fca.org.uk
• [6] content.govdelivery.com
• [7] a-teaminsight.com
• [8] afme.eu

What Changed

This is not a regulatory change but an enforcement of existing requirements under the German Commercial Code (HGB): Section 325 HGB: Mandates submission of accounting documents (e.g., annual financial statements, management reports) for public disclosure via the Bundesanzeiger operator in electronic form within prescribed deadlines (typically three months after fiscal year-end for annual reports). Section 335 HGB: Provides the legal basis for disciplinary fines by the BfJ for non-compliance, wit

What You Need To Do

• Verify internal processes for electronic submission of accounting documents to Bundesanzeiger within HGB timelines (e
• Implement automated reminders and dual-checks in finance/reporting workflows to prevent delays, especially during restructurings or audits
• Review and update compliance calendars for all HGB-disclosure obligations; conduct training for finance teams on section 325/335 HGB
• Monitor Bundesanzeiger portal for submission confirmations and retain proofs of timely filing to defend against BfJ inquiries
• For firms like BayWa in StaRUG proceedings, coordinate with courts/legal advisors to file provisional disclosures if full audits are delayed

Key Dates

References

• [1] lesechos-comfi.lesechos.fr
• [2] baywa.com
• [3] baywa.com
• [4] us.baywa-re.com
• [5] baywa-re.com

What Changed

The Federal Office of Justice enforced section 325 of the German Commercial Code, which requires companies to submit their accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form within the prescribed period.

What You Need To Do

• Ensure timely submission of accounting documents in electronic form to the German Federal Gazette
• Review internal procedures to guarantee compliance with section 325 of the German Commercial Code

Key Dates

Related Regulations

What Changed

This is not a regulatory change but an enforcement of existing requirements under the German Commercial Code (HGB): Section 325 HGB: Mandates submission of consolidated accounting documents (e.g., annual financial statements, management reports) for disclosure in electronic form to the Bundesanzeiger operator within prescribed periods (typically three months after fiscal year-end for AGs, i.e., by 31 March for calendar-year filers). Section 335 HGB: Provides the legal basis for disciplinary fine

What You Need To Do

• Verify filing processes
• Conduct gap analysis
• Train staff
• Monitor Bundesanzeiger confirmations
• No appeal if fined

Key Dates

References

• [1] investegate.co.uk
• [2] baywa.com
• [3] freshplaza.com
• [4] us.baywa-re.com
• [5] geschaeftsbericht.baywa.com
• [6] baywa.com

What Changed

The Federal Office of Justice imposed a disciplinary fine due to a breach of section 325 of the German Commercial Code, which requires companies to submit their consolidated accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form within the prescribed period.

What You Need To Do

• Ensure timely submission of consolidated accounting documents for the purpose of disclosure to the operator of the German Federal Gazette in electronic form
• Review and update internal procedures to comply with section 325 of the German Commercial Code

Key Dates

Related Regulations

What Changed

This is not a regulatory change but rather an enforcement precedent establishing that: "Scaffolding" strategy is prosecutable: Repeatedly placing and cancelling trading orders at progressively higher prices constitutes false trading under section 295 of the Securities and Futures Ordinance. Wash trading across multiple accounts is actionable: Using various securities accounts to simultaneously act as both buyer and seller of shares violates false trading prohibitions. Price impact + market de

What You Need To Do

• *For brokers and licensed intermediaries
• *Enhance surveillance systems to detect scaffolding patterns (repeated placement and cancellation of orders at progressively higher prices)
• *Monitor cross-account trading to identify wash trading where the same beneficial owner trades with themselves across multiple accounts
• *Implement controls to flag suspicious trading activity that artificially impacts share prices without genuine economic purpose
• *Document compliance procedures for detecting and reporting false trading under section 295 of the Securities and Futures Ordinance

Key Dates

References

• [1] fxnewsgroup.com
• [2] fxnewsgroup.com
• [3] sfc.hk
• [4] apps.sfc.hk
• [5] caproasia.com
• [6] mas.gov.sg
• [7] wikifx.com
• [8] caproasia.com

What Changed

The SFC has successfully prosecuted a case of false trading under section 295 of the Securities and Futures Ordinance, which constitutes an offence.

What You Need To Do

• Implement or review existing controls to detect and prevent false trading, including monitoring for suspicious trading patterns such as 'scaffolding' and wash trades
• Provide training to trading staff on the risks and consequences of false trading

Key Dates

Related Regulations

What Changed

The regulatory statement establishes the following key positions: Non-prioritization of CA98 investigation: The FCA, PSR, and CMA have jointly confirmed they will not prioritize competition law enforcement against UKPI's centralized access fee model for Phase 1/Wave 1 cVRPs (limited to "lower risk" use cases). Scope limitation: The regulatory clarity applies only to Phase 1/Wave 1 of UKPI's cVRP scheme, specifically addressing lower-risk payment use cases including regulated financial services

What You Need To Do

• *For UKPI and participating firms
• *Governance documentation
• *Pricing methodology transparency
• *Phase 1/Wave 1 compliance
• *Market engagement

Key Dates

References

• [1] fca.org.uk
• [2] regulationtomorrow.com
• [3] psr.org.uk
• [4] asima.co.uk
• [5] financialregulation.linklaters.com
• [6] fca.org.uk

What Changed

The FCA and PSR have clarified their enforcement position on the UKPI's proposal for a commercial model for cVRPs, indicating they will not prioritize a Competition Act 1998 investigation at this stage.

What You Need To Do

• Monitor market developments and updates on the legislative framework for open banking
• Review and understand the implications of the centralised 'access fee' pricing model for cVRPs on your business operations
• Ensure compliance with existing competition laws and regulations

Key Dates

Related Regulations

What Changed

*Credit Risk Framework** Implementation of restrictions on Internal Ratings-Based (IRB) approach scope, effective 1 January 2027, with firms required to reclassify certain exposures (e.g., slotting approach IPRE exposures) as High-Volatility Commercial Real Estate (HVCRE) where applicable. Minor clarifications and amendments to the Standardised Approach and credit risk mitigation techniques. *Operational Risk** Updated Business Indicator Component (BIC) calculation methodology requiring inclusi

What You Need To Do

• *Immediate (by mid-2026)
• *Conduct impact assessment
• *Review IRB permissions
• *Assess FRTB-IMA readiness
• *Arrange board-level assurance

Key Dates

References

• [1] bankofengland.co.uk
• [2] bankofengland.co.uk
• [3] grantthornton.co.uk
• [4] tlt.com
• [5] regulationtomorrow.com
• [6] rics.org
• [7] finreg.aoshearman.com
• [8] afme.eu

What Changed

The PRA has introduced new rules for the calculation of risk-weighted assets, including changes to the credit risk standardised approach, market risk framework, and operational risk requirements. The rules also include amendments to the definitions of probability of default, loss given default, and conversion factor.

What You Need To Do

• Review and update credit risk policies and procedures to ensure compliance with the new standardised approach
• Assess the impact of the new market risk framework on trading book positions and capital requirements
• Update operational risk management frameworks to reflect changes to the Business Indicator and subcomponents

Key Dates

Related Regulations

What Changed

*Restatement of CRR Provisions** The PRA is transferring remaining CRR requirements from the UK CRR into the PRA Rulebook without material changes to policy substance, except for targeted securitisation amendments. This follows the earlier PS12/25, which finalised the first tranche of restatement requirements in 2026. *Policy Materials and Supervisory Guidance PS3/26 introduces or amends multiple supervisory statements and statements of policy: New: SS4/24 (Credit risk: Internal Ratings Based A

What You Need To Do

• *Immediate (by Q2 2026)
• *Review applicability
• *Assess impact
• *Identify policy changes
• *Medium-term (by Q3 2026)

Key Dates

References

• [1] regulationtomorrow.com
• [2] bankofengland.co.uk
• [3] grantthornton.co.uk
• [4] slaughterandmay.com
• [5] bankofengland.co.uk
• [6] addleshawgoddard.com
• [7] prarulebook.co.uk

What Changed

The PRA has restated the remaining relevant provisions in the CRR within the PRA Rulebook and other policy materials, including amendments to supervisory statements and the introduction of new statements of policy. The changes include updates to the securitisation requirements and the introduction of new rules on credit risk and internal ratings-based approaches.

What You Need To Do

• Review and update internal policies and procedures to ensure compliance with the restated CRR provisions
• Ensure that risk management practices are aligned with the updated rules on credit risk and internal ratings-based approaches
• Review and update securitisation policies and procedures to ensure compliance with the amended requirements

Key Dates

Related Regulations

What Changed

The enforcement actions establish precedent in three critical areas: *Market Manipulation (Spoofing): The CFTC secured consent orders against precious metals futures traders for spoofing—placing and canceling orders to create false market impressions. The orders impose three-year and six-month trading bans** and require cease-and-desist compliance with the Commodity Exchange Act's spoofing prohibition. *Misappropriation and Fictitious Trading: The CFTC obtained permanent injunctive relief requ

What You Need To Do

• *For Registered Futures Firms and Banks
• trade and post-trade compliance controls
• *For Commodity Pool Operators and Investment Advisors:
• by-jurisdiction licensing analyses before soliciting investors
• *For All Market Participants

Key Dates

References

• [1] cftc.gov
• [2] jdsupra.com
• [3] cftc.gov
• [4] foley.com
• [5] lowenstein.com
• [6] cftc.gov
• [7] cohenco.com
• [8] cftc.gov

What Changed

The CFTC has obtained federal court orders imposing civil monetary penalties and trading bans on individuals and firms for spoofing and misappropriating confidential information. The CFTC has also charged an unregistered commodity pool operator with fraud and registration violations.

What You Need To Do

• Verify registration with the CFTC at NFA BASIC before committing funds
• Review and update anti-spoofing and anti-fraud policies and procedures
• Ensure compliance with CFTC regulations regarding commodity pool operations and futures market participation

Key Dates

Related Regulations

What Changed

The regulatory landscape has evolved significantly with the introduction of new sustainability reporting requirements: ESRS Implementation (First Year): 2024 marked the first full reporting year under the European Sustainability Reporting Standards (ESRS), with the CSSF conducting a fact-finding exercise to assess reporting quality. The CSSF noted an overall increase in reporting quality with better-structured reports and more relevant disclosures, though key improvement areas remain in compreh

What You Need To Do

• *Financial Information (IFRS)
• *Enhanced Note Disclosures
• *Cash Flow Statement Presentation
• *Segment Reporting Completeness
• *Going Concern Assessment

Key Dates

References

• [1] cssf.lu
• [2] bsp.lu
• [3] cssf.lu
• [4] lexgo.be
• [5] cssf.lu
• [6] lsfi.lu
• [7] cssf.lu
• [8] cssf.lu