ClearstreamXact: Enhanced beneficial owner disclosure for the U.S. market - update
Note: This announcement, originally published on 18 November 2024, has been amended to introduce further functionality details. Changes have been highlighted.
Clearstream Banking1 informs clients that effective
18 November 2024
that beneficial owners (BOs) in the U.S. market can now be disclosed using the formatted BO section of an MT565 or Xact Web Portal CA Instructions.
Each BO is assigned a Unique BO ID by Clearstream Banking which can be used in formatted disclosures.
Formatted messages are processed STP (straight-through-processing) and feedback will be provided for both accepted and rejected disclosures.
Impact on clients
STP BO Disclosure (U.S. market)
To provide beneficial owner information in an MT565 or an Xact Web Portal CA Instruction, Clearstream Banking offers a choice between two schemes:
- a Unique BO ID assigned by Clearstream Banking to every beneficial owner on record
- U.S. TINs for beneficial owners documented with a W-9 form
BO disclosure using Xact via Swift
The following table describes the option and format to be used for each scheme.
Beneficial owner identified with: | ||
Clearstream Banking Unique BO ID | U.S. TIN (BOs with a W-9 form) | |
(Sequence C: BENODET) | ||
Tax ID number | :95R::OWND/CEDE/ | :95S::OWND/TXID/US/ |
Quantity of Securities Owned | :36B::OWND | :36B::OWND |
Examples: | ||
| | :16R:BENODET :95R::OWND/CEDE/123456 :36B::OWND//UNIT/300, :16S:BENODET | Social Security Number (SSN) :16R:BENODET :95S::OWND//TXID/US/123-45-6789 :36B::OWND//UNIT/300, :16S:BENODET Employer Identification Number (EIN) :16R:BENODET :95S::OWND//TXID/US/12-3456789 :36B::OWND//UNIT/1500, :16S:BENODE |
Important Note: Option :95V: with names and addresses as narratives in an MT565 instruction is no longer supported and such messages will be rejected.
BO disclosure using Xact Web Portal
The following table describes the fields to be used for each scheme in the Xact Web Portal.
Beneficial owner identified with: | ||
Clearstream’s Unique BO ID | US TIN (BOs with a W-9 form) | |
(Section: Beneficial owner details) | ||
Tax ID number | BO_ID | BO_TIN BO_TIN_Country |
Quantity of Securities Owned | BO_Quantity_Type BO_Quantity_of_Securities_Owned | |
It is still possible to disclose Beneficial Owners using First and Last Names, however, the Beneficial Owner Lookup tool (accessible with the spyglass icon) must be used.
The Name and Address can no longer be inserted in the Narrative field (accessible with the pencil icon) for US disclosures and will cause such instructions to be rejected.
First and Last name as well as any other field can be used to research Beneficial Owners linked to the instructed account.
If no search value is entered, the tool returns all the Beneficial Owners linked to the account and one or multiple returned Beneficial Owners can easily be selected and added to the instruction.
The quantity owned by each Beneficial Owner can be added when returning to the CA Instruction screen.
Beneficial owner disclosures can be built in Xact Web Portal or prepared off-line and imported via the available template.
The possibility to run preliminary certification checks on selected beneficial owners is extended to the U.S. market.
Up to one hundred beneficial owners can be disclosed in a single Xact Web Portal CA Instruction.
In line with client announcement C20025, if an instruction without disclosure that has been already sent and needs to be corrected before payment, it needs first to be cancelled (CANC) and a new instruction submitted (NEWM).
New beneficial owner search in Xact Web Portal
BO IDs have been provided in the narrative of certificate confirmations since the end of June 2024.
Clients can search and extract all or part of their beneficial owners on record with Clearstream from the "Beneficial Owner Query" within the Tax domain.
Once the desired beneficial owners list is returned by the query, the results list can be exported.
BO IDs can now also be used when looking for certificates in the Tax Certificate Query screen.
Clients can see the status of their BO disclosures in Xact Web Portal and receive MT567/CA Instruction Status
Feedback will be provided for every formatted beneficial owner disclosure, whether it has been processed successfully or if an error was encountered.
MT567 – Status of a Beneficial Owner disclosure in an MT567
CA Instruction Status | |||
Status | Accepted | Rejected | Rejected with Narrative |
(Subsequence A2a Reason: REAS) | |||
Status Code | :25D::IPRC//PACK | :25D::IPRC//REJT | :25D::IPRC//REJT |
Reason Code | n/a | :24B::REJT//CERT :24B::REJT//FULL :24B::REJT//LATE | :24B::REJT//CERT |
Reason Narrative | n/a | n/a | :70D::REAS//<rejection reason> e.g. :70D::REAS//Beneficial Owner certificate not found matching account and TCA BO ID 123456 |
Xact Web Portal – How to look for disclosure status
In Asset Servicing/Instruction/CA Instruction
CA Instruction Status | ||
Status | Recorded | Rejected |
Reason Narrative | n/a | e.g.: Beneficial Owner certificate not found matching account and TCA BO ID 123456 |
Unique BO ID and US TINs in free format disclosures
Unique BO IDs and US TINs can also be used in free format disclosures (MT568, MT599) as alternatives to first and last name.
Example 1:
List of Beneficial Owners using Clearstream BO ID
34567 20000
456789 5000
Example 2:
List of Beneficial Owners using US TINs
123-45-6789 20000
23-4567890 5000
Further information
Please refer to the Clearstream website for more information about Xact Web Portal or Xact File Transfer.
For further information, clients may contact Clearstream Banking Client Services or their Relationship Officer.
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1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking AG clients using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany, and registered in Register B of the Amtsgericht Frankfurt am Main, Germany, under number HRB 7500.