Consultation Paper High level description, Nordic CSD Corporate ...

Agent whenever an Issuing Agent is appointed. The second basic
responsibility of the Issuing Agent implies that it needs to have access to the
securities memorandum accounts for the relevant instrument, regardless of
which Account Operator holds the account and hence has the contractual
relationship with the end investor.
The purpose of the Issuing Agent model is to make processing of Corporate
Actions as efficient as possible since one participant takes care of investor
communication instead of many Account Operators or banks being involved.
An example would be that only one instruction form, decided upon by the
Issuer and Issuing Agent, would be distributed to the relevant investors and
intermediaries. Intermediaries would still be able to create their own
instruction forms to their clients, as there might be a need to set their own
deadlines to the clients. The Account Operators/Nominees will also receive
the instructions from the underlying clients. As the communication between
the Account Operators/Nominees and the nominee registered holders already
today follows international standards, the Account Operators/Nominees
should be able to forward the instruction directly to the CSD system.
However, those instructions will be viewable for the Issuing Agent as it has
to have the total view of the instructions related to the Corporate Action. In
some cases, the instructions from the Account Operators/Nominees should be
put on hold in the CSD system and released only by the Issuing Agent. The
rationale to implement this participant role is also stressed by the Nordic
feature with a vast amount of beneficial owner accounts on the CSD level that
leads to a vast amount of individual instructions in a Corporate Action.
page 24(62)