The intent of the 2/3s rule (or whatever we have to call it now) is that in the event of tube rupture (which is quite rare) is that the lower pressure side is not pressurized above its hydrotest pressure. If you remember that, you'll be fine.
All, the rule applies to the entire system including upstream and downstream piping that would be pressurized to the tube rupture pressure (whatever you work that out to be), you can't just stop at the exchanger's flanges and ignore everything else.