Non-Standard Case Spotlight: Holders of SNS REAAL and SNS Bank Debt Instruments

On February 1, 2013, the Dutch government nationalized SNS REAAL to avoid its insolvency and to stabilize financial markets. On March 1, 2013, the company’s debt securities ceased trading and lost their value, prompting litigation seeking recovery for certain debt holders that now, roughly a decade later, has resulted in a court-approved compensation fund of €804,810,000, with interest, to be distributed to eligible claimants by the Dutch Finance Ministry.

Non-Standard Recovery Opportunity

This non-standard recovery opportunity differs from other Dutch recovery efforts investors have seen in recent years, including Dutch Collective Settlements like Fortis and Steinhoff and representative suits by Foundations, Investor Associations, and special purpose litigation vehicles against companies like Petrobras and Philips.

This government compensation program is analogous to a regulatory UK Compensation Scheme or SEC Fair Fund. Like those passive matters, the recovery monies here have already been set aside for investors. The Dutch Finance Ministry will be accepting claims and distributing the money in accordance with a court-approved distribution plan. If eligible, claimants can participate without becoming parties to litigation, and there are no risks involved.


Eligible claimants include holders of:

  • SNS REAAL and SNS Bank subordinated bonds;
  • Certain unlisted subordinated bonds, issued by SNS Bank under the name “SNS Participatie Certificaten 3,” for which SNS Bank failed to fully compensate in 2013; and
  • Certain expropriated loans.

Upon request, FRT can provide a complete list of securities identifiers. SNS REAAL shareholders will not receive any compensation.

Recovery Process

If you were a holder of eligible securities on March 1, 2013, and continue to hold them with your custodian, the claims submission process is straightforward. You will receive a SWIFT message with a form to submit to the Corporate Action Agent (CAA). Once returned, the CAA will send a code to give your custodian, and the Finance Ministry will issue your payment through your custodian.

If you acquired eligible instruments by sale or assignment after March 1, 2013, there is a separate claim submission process through the compensation fund website. It requires significantly more time and effort, including providing identification information, a power of attorney, recent bank statements, and documents showing how you acquired ownership.

The latter claim submission process starts on May 15, 2023. Claims involving SNS REAAL and SNS Bank subordinated bonds must be submitted within six weeks thereafter. The holders of unlisted subordinated bonds or certain expropriated loans have different deadlines, to be provided by the Finance Ministry.


Please contact FRT if you hold these instruments and would like to receive a complimentary, detailed Alert with fuller details, or would like assistance submitting your claims.




Founded in 2008, Financial Recovery Technologies (FRT) is a leading technology-based services firm that helps the investment community identify eligibility, file claims and collect funds made available in securities and other class action settlements. Offering the most comprehensive range of claim filing and monitoring services available, we provide best-in-class eligibility analysis, disbursement auditing and client reporting, and deliver the highest level of accuracy, accountability and transparency available. For more information, go to


This communication and the content found by following any link herein are being provided to you by Financial Recovery Technologies (FRT) for informational purposes only and does not constitute advice. All material presented herein is believed to be reliable but FRT makes no representation or warranty with respect to this communication or such content and expressly disclaims any implied warranty under law. Opinions expressed in this communication may change without prior notice. Firms should always seek legal and financial advice specific to their unique situation and objectives.