France – CM PB – Update 2022

Jun 27, 2022

Dear Client,

We would like to inform you that BRP has updated its COUNTRY MANUAL PRIVATE BANKING for the following jurisdiction:

FRANCE OUT OF BANK’S COUNTRY OF ESTABLISHMENT (Def, RS, BT & RT)

  SOURCE OF CHANGES  ANSWERS
  Law/Regulation    No
  New Position of the Authorities    No
  Evolution of Expert’s interpretation    No

Regulatory Template, Regulatory Summary and Behaviour Template

Material changes

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date. We can confirm that there have not been any relevant legal or regulatory changes in France since the last update. 

For the activity of collecting/receiving a signed Lombard credit agreement, we have included the regulatory condition that the credit funds must not be disbursed on the client’s bank account in France in order not to breach the banking monopoly rules. This condition was added in order to ensure the alignment of answers with the CM Credits France.

Non-material changes

Several comments have been slightly reworded (without introducing material changes) to reflect the regulatory situation/current interpretation of the regulatory framework more accurately. 

Implications for business relations with third parties

With respect to the provision of documentation to the EAM (such as documentation on the Bank’s banking and investment services, investment research and financial analysis or recommendation lists), our Country Manual now distinguishes between the provision to the EAM for remittance to the end client on one hand and the provision to the EAM for the EAM’s own professional purposes on the other hand. The answers have been amended accordingly.

Regulatory Summary

This document has now a more user-friendly layout and reflects the changes contained in the RT.

BT Short Comparison

BRP has created a comparison document allowing users to quickly identify the modifications made compared to the previous version of the PB Manual (BT Short Comparison). The BT Short Comparison can be found on BRP’s platform (mybrponline) in the Search tab by entering in the Document Field “CM PB BT SHORT COMP” and “FRANCE” in the Target Country Field.

The BT Short Comparison should be read as follows:

The first column contains a short description of the activity in question. The second column contains the answers of the previous version of the Country Manual (online until the day of the alert). The third column contains the new answers of the most recent version of the Country Manual. Only the modified answers are displayed (in color). If the answers in the new version are unchanged compared to the previous version, they are shaded in grey.

For more information, please contact us: info@brpsa.com

Best regards,