Global Trustee and Fiduciary Services Bite-Sized Issue 5 2024

Global Trustee and Fiduciary Services Bite-Sized | Issue 5 | 2024 2 QUICK LINKS CYBERSECURITY DIVERSITY DORA ELTIF EMIR FINTECH FSB IOSCO SUSTAINABLE FINANCE/ESG UCITS ASIA EUROPE NETHERLANDS NORTH AMERICA UNITED KINGDOM The CFTC’s DEIA Plan, aligned to the CFTC’s 2022-2026 Strategic Plan, focuses on the following six goals: • Inclusive Workplaces; • Partnerships and Recruitment; • Paid Internships; • Professional Development and Advancement; • Data; and • Equity in Procurement and Customer Education and Outreach. The CFTC says that each goal includes objectives and strategies/actions to achieve the goal and identifies the CFTC’s division(s)/office(s) that will lead and contribute to the implementation of the goal. An internal DEIA Executive Council will support and guide the implementation of the DEIA Plan. Link to DEIA Strategic Plan here DORA ESAs to Run Voluntary Dry Run Exercise to Prepare Industry for the Next Stage of DORA Implementation On 11 April 2024, the European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) announced that they will launch in May 2024 the voluntary exercise for the collection of the registers of information of contractual arrangements on the use of ICT third-party service providers by financial entities. Under the Digital Operation Resilience Act (DORA) and starting from 2025, financial entities will have to maintain registers of information regarding their use of ICT third-party providers. In this dry run exercise, ESMA says that this information will be collected from financial entities through their competent authorities and will serve as preparation for the implementation and reporting of registers of information under DORA. ESMA states that the ESAs and the competent authorities are introducing this voluntary exercise to help financial entities prepare for establishing their register of information, gathering the relevant information specified in the ESAs’ final draft Implementing Standards on the registers of information and reporting their registers of information to their respective competent authorities, who will, in turn, provide those to the ESAs. ESMA says that financial entities participating in the dry run will receive support from the ESAs to: 1. Build their register of information in the format as close as possible to the steady-state reporting from 2025, 2. Test the reporting process, 3. Address data quality issues, and 4. Improve internal processes and quality of their registers of information. As part of the exercise, the ESAs will provide feedback on data quality to financial entities participating, return cleaned files with their register of information, organise workshops and respond to frequently asked questions. Following the launch of the ad-hoc data collection in May 2024, financial entities will be expected to submit their registers of information to the ESAs through their competent authorities between 1 July and 30 August. Also, on 17 April 2024, the Luxembourg Commission de Surveillance du Secteur Financier (CSSF) announced that it would like to draw attention to the announcement by the ESAs of the voluntary exercise for the collection of the registers of information of contractual arrangements on the use of ICT third-party service providers by the financial entities serving as preparation for the implementation and reporting of registers of information under DORA.