Global Trustee and Fiduciary Services Bite-Sized Issue 12 2023

Global Trustee and Fiduciary Services Bite-Sized | Issue 12 | 2023 15 QUICK LINKS AIFMD BENCHMARK REGULATION CBDC COSTS & CHARGES CRYPTOASSETS FUND LIQUIDITY LIBOR TRANSITION MiCA OPERATIONAL RESILIENCE UK PRIIPs SUSTAINABLEFINANCE/ESG ASIA EUROPE IRELAND NORTH AMERICA UNITED KINGDOM The notes aim at setting out factual information regarding these concepts and providing helpful aide to stakeholders to navigate and better understand the Sustainable Finance legislative framework. ESMA notes that these documents are purely descriptive and they are not intended to replace relevant legal texts nor to provide guidance on the application of relevant provisions. Link to Definition of Sustainable Investments here Link to Application of DNSH Requirements here Link to Use of Estimates here MAS Launches Digital Platform for Seamless ESG Data Collection and Access On 16 November 2023 the Monetary Authority of Singapore (MAS) launched Gprnt (pronounced “Greenprint”), an integrated digital platform that aims to simplify how the financial sector and real economy collect, access and act upon ESG data to support their sustainability initiatives. MAS notes that Gprnt is the culmination of its Project Greenprint and offers an enhanced digital reporting solution for both large businesses and small and medium enterprises (SMEs) to seamlessly report their ESG information. When fully implemented, Gprnt’s reporting solution is expected to help companies automate their ESG reporting process, and allow end users (such as financial institutions, regulators and large corporates) to access relevant data and timely insights to support their sustainability- related decision making. Following its launch, Gprnt will expand its cross-border capabilities to better serve the more sophisticated data needs of larger multi-national entities and other regional economies. To achieve this, a new entity, Greenprint Technologies Pte Ltd, will be set up. The new entity will closely engage key financial institutions and technology providers to drive the adoption of Gprnt’s automated disclosure solution. Link to Announcement here FCA Finds Further Work Required to Fully Embed ‘Guiding Principles’ for ESG and Sustainable Investment Funds On 16 November 2023 the FCA published the findings from its supervisory work that looked at how Authorised Fund Managers (AFMs) comply with existing regulatory requirements and expectations on the design, delivery and disclosure of Environmental, Social and Governance (ESG) and sustainable investment funds. The FCA review found evidence of good practice, such as the development and use of appropriate ESG and sustainability scoring systems and benchmarks. The review also highlighted good practice where AFMs conducted thorough due diligence on third party data providers. The FCA notes that, while progress has been made, many firms still have further to go to meet its expectations, particularly around the disclosure and clarity of information being given to retail investors and consumers. The FCA has found other examples of poor practice including: • Products were inconsistently aligned with their ESG and sustainability goals even if they referenced them in their name. • In some instances, fund holdings appeared inconsistent with a fund’s ESG or sustainability objectives, and some AFMs weren’t able to explain how these investments fit with their goals. • Key ESG and sustainability information was often not explained, put into context or included in disclosures, meaning relevant information was not immediately or clearly accessible to investors. • The design of AFMs’ stewardship approaches did not meet the FCA’s expectations. It was often difficult to identify the exact aim of the stewardship activities, how the activities were aligned to fund objectives, and examples of the progress they made against those aims. The FCA expects firms to address the good and poor practices outlined in the report to meet the requirements of SDR and the Consumer Duty. Link to the Review Findings here