If the security principals used for RMS are global address list (GAL) members, is there any dependency on the version of Exchange?
RMS depends on Active Directory but not Exchange. However, Exchange 5.5 maintains its own directory and does not use Active Directory. Ensure that all of the user and group objects in Active Directory have a valid e-mail attribute that includes the fully qualified domain name. This is done automatically if you are using Exchange 2000 or later.