GRC Report Staff

EIOPA has confirmed that the SE.01.01 closed list will not yet include "Not due in accordance with instructions of the template" for S.36.05, even though Taxonomy v2.10.0 now treats S.36.05 as not due when its content is already reported in other S.36 templates. Any change is deferred to the next ITS amendments. Insurers must therefore use a workaround for now, and should plan for how it will be perceived by supervisors.

ASIC's Form 390 is the annual notice a holding entity must lodge when it does not prepare consolidated financial statements and its wholly-owned subsidiaries rely on relief under Instrument 2016/785. The notice must be lodged within 4 months after financial year-end, and it carries director-level attestations about the Deed of Cross Guarantee and the solvency of the Extended Closed Group. Compliance teams should confirm eligibility and lodgement processes so that subsidiary reporting relief is not lost.

ASIC has published Form 362/486 and an updated guide (dated April 2, 2025) for Australian companies that nominate or cease a registered agent or contact address. The update is administrative, but it affects corporate key handling and where ASIC sends official correspondence. Compliance teams should confirm that agent changes are lodged correctly so statutory notices are not missed.

FinCEN led a FinCEN Exchange with global financial institutions on September 16, 2026, to share information on the nodes, facilitators, and networks that give Iran and its proxies access to U.S. correspondent banking. The event creates no new legal obligations, but FinCEN strongly encourages institutions to review its Iran-related alerts, advisories, and trend analyses along with OFAC sanctions. Compliance teams should treat it as a signal of heightened enforcement and supervisory attention on Iran exposure.

ASIC's Form 5231 lets a member of a retail corporate collective investment vehicle (CCIV) notify ASIC of an auditor appointment when none is in place, as required by the Corporations Act 2001. The form is dated 1 July 2022, so it is an existing form, not a new rule, even though the feed shows a 2026 date. It matters because a missing auditor is a statutory gap in a retail CCIV's governance and needs a prompt, properly documented fix.

Commissioner Hester Peirce issued a statement supporting SEC proposals to rescind Exchange Act Rule 14a-8, the federal mechanism for shareholder proposals in company proxy materials, and to simplify other proxy solicitation requirements. If adopted, authority over shareholder proposal access would shift largely to state law and company governance. Compliance and corporate governance teams should prepare for a period of uncertainty and a changed engagement model. The statement is a commissioner's views on proposals, not a final rule, and no effective dates are given.

EIOPA's final Q&A (ID 3567) confirms that bonds on the balance sheet but lent out through repurchase or securities lending transactions must be included in the CSSR numerator for the revised volatility adjustment. Derivative bond exposures, such as forward purchases, are excluded. Insurers should align their CSSR methodology and data processes with this interpretation before the January 2027 implementation date.