BPCE - 2019 RISK REPORT Pillar III

NON-COMPLIANCE AND SECURITY RISKS

COMPLIANCE

In conjunction with the calculations and other work done in Volcker rule: the ban on proprietary trading and on certain accordance with this act, an enhanced compliance program was activities related to covered funds.

adopted and implemented as from July 2015 in response to the Volcker rule (a sub-section of the US Dodd-Frank Act) within the scope of BPCE SA and its subsidiaries. Taking a broader approach than that of the French Banking Separation and Regulation Act, this program aims to map out all the financial and commercial activities of BPCE SA group, notably to ensure that they comply with the two major bans imposed by the

In March 2019, the Group certified its compliance with the Volcker rule with the US regulator, as it has every year since July 2015. Note: in early 2017, Groupe BPCE appointed a SRAB-Volcker officer responsible for the security of the banking segregation mechanisms. This officer also oversees the requirements set forth by US regulations on Legal Entity Management (LEM).

Insurance compliance

The Insurance Compliance department ensures that insurance products are marketed in compliance with applicable regulations. Insurance Compliance prepares fundamental guidelines stipulating the disclaimers that have to be included in advisory notices for Group products. It provides regulatory and operational support to Group entities, mainly by issuing normative recommendations and transposing them into operating practices. It also takes part in the Group New Product Committee and in commercial processes, verification of sales processes, and validation of training modules covering advertising media and network documents.

insurance advisory obligations, and ORIAS registration obligations. The Insurance Compliance division handled the operational implementation of regulatory requirements: operational implementation of the standard pertaining to • customers aged 80 or more; optimization of the customer experience in terms of insurance • management procedures; improvement of the customer experience in terms of financial • savings products; annual insurance fee statements. •

HIGHLIGHTS

In 2019, normative recommendations focused on payment protection insurance, product governance and supervision,

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RISK REPORT PILLAR III 2019 | GROUPE BPCE