France: Enhancement of General Meeting electronic invitation
Clearstream Banking1 informs clients that the French market has reached an agreement and is preparing to publish a decree allowing issuers to electronically communicate with shareholders of French registered securities about forthcoming general meetings.
Clearstream Banking in its role in the French market must comply with this change, effective
immediately
Impact on clients
Issuers are requesting shareholders to provide three new personal data values to complete the information stored at the registrar’s:
- Date of birth;
- Telephone number;
- Email address.
This is expected to be handled in two steps to ensure that all the necessary actions to collect and process these three new data values have been undertaken when the French Decree is officially published (expected by end of Q1 2025).
First step, starting immediately
The required information will be collected through the custody chain from the shareholders and sent to Clearstream Banking via email containing the attached template:
- All BO data values which are considered as mandatory (highlighted in green) in the attached Excel template “Fichier de transmission des données aux Teneurs de Registre (TDR)” and only that one, must be completed with the BO details available from the “Registered Securities: Beneficial Owner Details” query in Xact Web Portal.
Note:
a. Incorrect or wrongly formatted information in the file may lead to the rejection of the file.
b. For guidance purposes, some fields in the template have been pre-filled with sample data. - The date of the data extraction from Xact Web Portal must be quoted in the Excel file.
- Potential changes to BO data other than birth date, phone number and email, not yet reflected in Xact Web Portal, must be submitted via free format message after completion and transmission of the Excel file.
- The file (see attached template) must be completed for each CBL, CBF-i or CBF account holding French registered securities and sent back to Clearstream Banking by 17 April 2025 close of business to the following email address: frsdata@clearstream.com.
Note: Information received after that date will be handled on a case-by-case basis leading to potential delays in the submission to the registrars. - To ensure a smooth and timely handling, clients are recommended to:
a. Use the following subject in the email: "FRS DATA – REGISTERED ACCOUNT xxxxx (CBL/CBF-i) or xxxx-203 (CBF)";
b. Use one file per account and per email. - To ensure data protection, Clearstream Banking requires the use of the Excel template with a protected password.
- The password will be transmitted to Clearstream Banking via telephone to Client Care Prague/Sabina Novotna on +420 29 64-2 91 33 quoting also the date when the file was sent.
Second step
Euroclear France will enhance its system to update the BRN (Bordereau de Reference Nominative) files and those three new data values will be included in all BRN exchange files. This change is expected to take place by Q4 2025.
Xact Web Portal will be enhanced to process these three new fields in due course.
Important note:
Despite this market change, Clearstream Banking reminds clients that no service of proxy voting for French registered securities is offered for the time being.
Clients holding VEN (Valeurs Essentiellement Nominatives) are not required to populate these details (see list attached below).
Further information
For further information, please contact your dedicated Client Service Officer or Relationship Officer.
------------------------------------------
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, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany, and registered in Register B of the Amtsgericht Frankfurt am Main, Germany, under number HRB 7500.