It seems to me that the pressure regulator upstream of the exchanger will only regulate the pressure coming from that direction.
If the valve is downstream of the exchanger and it's slammed closed, then the pressure pulse is coming from the other side of the exchanger and must pass through the exchanger before it hits the regulator, so it's inconsequential to what the exchanger sees in this situation, even if it works to regulate pressures bi-directionally. If there is no relief device between the valve and the exchanger, then I'd think that the exchanger could see extremely high pressure spikes if that valve is suddenly closed.
If there is a relief device, then the pressure that the exchanger would see would be affected by the type of device it is, its set points, and the operating characteristics of the device (for instance, does it begin opening at 150 or is it fully open at 150?).
Of course, I've been wrong before.