REG S/Rule 144A exchanges: Introduction of new asset servicing flows
Where securities are issued under both Regulation S and Rule 144A, clients have the possibility to exchange all or part of their position held under the Regulation S Global Note into the Rule 144 Global Note, or vice versa.
LuxCSD1 informs clients that effective
24 November 2025
the current processing and reporting for the exchanges from Reg S to Rule 144A Notes and vice versa will be enhanced.
Current situation
Clients are requested to send free-format messages for the following exchanges:
- From XS ISIN to XS ISIN;
- From XS ISIN to US ISIN;
- From US ISIN to XS ISIN;
- From US ISIN to US ISIN.
For US-to-US exchanges, clients can also send settlement instructions MT540/542.
Paperwork, if any, must be handled by the clients themselves, while the execution of the exchange is confirmed via standard settlement reporting.
Service Description
Whenever applicable and known to LuxCSD, the conditions of the exchanges Reg S to 144A or 144A to Reg S, will be announced to clients via Corporate Action event (MT564/seev.031):
- CONV VOLU
If the original ISIN can be exchanged into two different ISINs, a separate event will be created for each resulting ISIN.
Clients will be required to instruct via MT565/seev.033. In their instructions the clients will need to confirm the compliance with the required certification and to provide necessary details for the exchange in the narrative fields or MX equivalent.
:70E::INST//Certification confirmation: Certification OK
:70E::PACO//Contact details
The status of the instruction will be reported to clients via MT567/seev.034. The standard recycling rules will be applicable in case of insufficient securities balance on the client account.
Once the exchange is executed and completed, clients will receive MT566/seev.036.
Standard fees for formatted corporate action instructions will apply. Unformatted instructions will be charged at the standard free-format message fee.
Benefits for clients
The new process will allow clients to:
- Benefit from the end-to-end corporate action flows covering the exchange request and execution;
- Apply a consistent process for all exchanges;
- Instruct via a structured message (MT565/ seev.033);
- Monitor the status of the exchange (MT567/ seev.034);
- Delegate the paperwork to LuxCSD as part of new service.
If no event is announced by LuxCSD, clients can send an unsolicited instruction, that is, via MT565/seev.033 to request the exchange mentioning the following details.
:70E::INST//1. Resulting ISIN code, 2. Certification confirmation: Certification OK
:70E::PACO//Contact details
Note: For the US-to-US exchanges, the existing settlement instruction MT540/542 will be kept in parallel to the new asset servicing process.
Further information
The Client Handbooks and Market Link Guide will be updated accordingly.
For further information, please contact the LuxCSD Client Services or your Relationship Manager.
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1. LuxCSD refers to LuxCSD S.A., registered office at 42, Avenue J.F. Kennedy, L-1855 Luxembourg, registered with the Luxembourg Trade and Companies Register under number B-154.449.