Sia Partners volcker rule implementation

Volcker Rule March 2015

Daniel H. Connor

Shane C. Williams

Aurelien Borde

Head of US Operations

Associate Partner

Senior Manager

Tel: (862) 596-0649 Mail: daniel.connor@sia-partners.com

Tel: (917) 701-7700 Mail: shane.williams@sia-partners.com

Tel: (917) 935-8855 Mail: aurelien.borde@sia-partners.com

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Volcker Rule – Meeting the compliance deadline

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Volcker Rule – Meeting the compliance deadline Most banks have completed the design of their Volcker Compliance Program, and are now in the implementation phase: Design

Policies and Procedures

Inventory existing P&Ps & Establish gap analysis

Determine list of required P&Ps

Internal Controls Management Framework

Implementation Draw documentation plan

Implement documentation plan

Determine limits and controls

Implement limits and controls

Establish Management Framework

Implement Management Framework

Training

Define training approach

Produce training material

Testing

Define testing strategy

Implement tests

Record Retention

Determine record retention requirements

Metrics Reporting

Perform training

Perform tests

Implement record retention

Determine roles & responsibilities Define calculation assumptions

Implement IT Solution

Write business requirements

Today

July 21st, 2015

The end of the Conformance Period is approaching fast, and for most Banks, meeting the Compliance deadline is a challenge considering the amount of work that remains to be accomplished.

Sia Partners has the knowledge and capabilities to assist Banks in the implementation of their Volcker Compliance Program.

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Volcker Rule – Meeting the compliance deadline Focus on Policies and Procedures

Record Retention

Policies and Procedures Internal Controls

Testing

Training

Management Framework

Policies and Procedures Documents detailing the requirements and processes designed to prevent prohibited trading activities and specific investments: • Desk Level policies & procedures; general policy & checklist of requirements per exemptions • Desk level documentation in line with desk level policy including RENTD justification for market-making desks • Policy documents needed for new products • Covered Funds documentation • HR Control policies and procedures • Liquidity Management Policies and Procedures • Control and Monitoring Policies and Procedures

Key Considerations • Trading P&P must include the essentials i.e., identify authorized products that can be purchased or sold, mission of the trading desk, identification of trading desks, identify risk and size limits, etc.

• Hedging P&P must include description of positions, techniques and strategies that will be used, how the banking entity identifies risks, what level will hedging activity take place, monitor and review procedures, how the hedges are developed, documented, tested for effectiveness, approved and reviewed.

• Risk management P&P must include description of governance, reporting, escalation, review and other processes to ensure compliance, how internal valuation models and risk limits are developed, documented, tested and approved.

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Sia Partners Approach / Added Value Sia Partners documents and evaluates existing procedures, and updates and adds where necessary to ensure compliance.

• Leverage Front Office policies and procedures to develop F/O policies and procedures.

• Support functions policies, procedures and controls will be synchronized to support front office and demonstrate that key support areas are independent of Front Office.

Typical estimated timeline is about 2 months.

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Volcker Rule – Meeting the compliance deadline Focus on Internal Controls

Record Retention

Policies and Procedures

Internal Controls

Testing

Training

Management Framework

Internal Controls Monitor compliance with the rule and preventive measures to reduce the occurrence of activities or investments that are prohibited: • Define and implement controls on the desk mandates • Define and implement controls on the 7 Volcker metrics • Define and implement controls on RENTD • Develop monitoring Controls • Assist in Developing IT Automation

Key Considerations • • •

•

Ensure all trading controls include measures / steps to control that activity is in line with policies and procedures.

Ensure controls relating to hedging activity are designed to track the adherence to internal policies and procedures and include how related analysis will be conducted and frequency.

Ensure controls related to covered funds: • Monitor individual and aggregate investments in covered funds, • Calculate individual and aggregate ownership interests, • Include requirements relating to sponsoring, underwriting and market making activity, • Include pro-active measures to ensure that a covered fund can be purchased by the banking entity.

Ensure that risk management controls include model validation, establishing risk limits and ensuring adherence to these limits.

Sia Partners Approach / Added Value Sia Partners documents and evaluates existing controls, and updates and adds where necessary to ensure compliance.

1. Leverage process utilized in evaluating Front Office policies and procedures.

2. Work with Front Office support areas in developing procedures and adequate controls.

• • •

3.

Work with IT for automation. Ensure that Front Office support areas are fully engaged in this process.

• • • •

4.

Assist in creation / modification of existing reports.

Automation should capture description of instruments, CUSIPs, holding period calculations, etc.

Assist in capture of customer volume metrics for RENTD requirements.

Work with support area managers to ensure respective groups can immediately implement controls.

Deliver listing of Controls to Internal Audit Group: • •

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Develop procedures to evaluate investing / market making activity.

Develop procedures to evaluate covered funds, i.e., CLOs. Controls must fit within existing framework of support area.

Identify internal controls.

Ensure proposed controls meet Internal Audit standards.

Typical estimated timeline is about 2 months.

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Volcker Rule – Meeting the compliance deadline Focus on Management Framework

Record Retention

Policies and Procedures

Internal Controls

Testing

Training

Mgmt Framework

Management Framework Represents the CEO Certification and establishes clear responsibilities and accountability for compliance with the rule including management reviews of trading limits, strategies, hedging activities and other similar matters 1. FO Governance for 1st level of control 2. Group & Firm-wide governance – define overall governance and determine governing body for Volcker compliance 3. Sub-Certification process

Key Considerations 1. Identification of personnel responsible for effective implementation and enforcement of compliance program.

• Include personnel qualifications and responsibilities.

2. Identify reporting line and chain of responsibility.

3. Identification of escalations.

4. Identify parties responsible for policies and procedures.

5. Identify Management Systems.

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Sia Partners Approach / Added Value Using a “Two in a Box” approach Sia Partners works with internal compliance partner to set up the management framework..

1. Assist Senior Management in connecting dots between Front office and key support areas with all compliance program components.

• Provide linkage between Front Office activity and how support areas will validate and monitor activity for Volcker Rule compliance • Demonstrate to Senior Management that adequate escalation procedures are in place to ensure critical communication can be carried out.

2. Ensure relevant parties understand what their responsibilities will be under the new Volcker Rule regime.

Typical estimated timeline is about 1 month.

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Volcker Rule – Meeting the compliance deadline Focus on annual CEO Attestation – Proposal of a sub-certification process CEO

Step 4: CEO Before March 31, 2016

Step 3: Executive Committees Q1 2016

Written certification that the Bank establishes, maintains, enforces, reviews, tests and modifies a Volcker compliance program

Risk Committee Written certification that the Bank monitors its trading activities and the related risks

Compliance Committee

Step 2: Business Groups Q1 2016

Step 1: Trading Desks December 31, 2015 CONFIDENTIAL Š Sia Partners

Business Group 1

Business Group 2

Written certification that trading activity is monitored and that policies and controls are in place to ensure that no covered fund activity is performed

Written certification that trading activity is monitored and that policies and controls are in place to ensure that no covered fund activity is performed

Trading Area 1

Trading Area 2

Written certification that metrics and indicators are in place at the desk level to monitor the trading activity

Written certification that metrics and indicators are in place at the desk level to monitor the trading activity

Business Group 3 Written certification thatWritten policiescertification and controls are in place thatWritten policies and certification to ensure that controls arenoin place that policies and trading or covered to ensure that controls arenoin place fundtrading activity oriscovered to ensure that no performed fundtrading activityoriscovered performed fund activity is performed

Written certification that the Bank reviews and tests its compliance with Volcker as part of the compliance testing and monitoring program

Audit Committee Written certification that the Bank conducts independent testing and audit regarding its compliance with the Volcker Rule

Compensation Committee Written certification that the Bank incentive compensation plans comply with the Volcker Rule

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Volcker Rule – Meeting the compliance deadline Focus on Enhanced Reporting Requirements Metrics Reporting Summary Table Metric

Effort Rating

Risk & Position Limits

Rationale

Notes

VaR & Stress VaR

Core operational and risk management metrics collected already, but additional effort may be needed to standardize and aggregate new reports and establish monthly/quarterly reporting process and quality assurance reviews

When criteria other than VaR and Risk Factor Sensitivities are used to set risk or position limits, the values of both the limits and the variables assessed against the limits must be reported

Risk Factor Sensitivities

Currently collected as a core risk metric, but greater effort will be needed to standardize risk factor sensitivities across Trading Desks and systems

Standardization across desks and businesses will create issues in many organizations as there are often good reasons for different methodologies used (e.g. flow versus structured desks)

Comprehensive P&L Attribution

Multi-level attribution of daily P&L is consistent with existing approaches at most banking entities, but mapping to three required categories and aligning sub-attribution may require additional effort and IT investment

Comprehensive P&L attribution and volatility over 30, 60 and 90 day periods (lagging) are required for this reporting metric; new position P&L may require updates to risk systems to separate new positions

Inventory Turnover

Inventory turnover is a metric that is not currently calculated – particularly for derivatives – in most organizations

While the calculation is not complex, substantial effort may be required to develop the data feeds and aggregation capabilities to calculate daily and report the results as required

Inventory Aging

Aging of securities inventory is common for many organizations but not for derivatives at the instrument level – implementation of the derivative “value” calculations could require substantial effort

Separate schedules for assets and liabilities are required and organizations must decide on aging method to be adopted – e.g. LIFO or FIFO – and how that will apply to derivative positions

Customer Facing Trade Ratio

This is an entirely new metric for most organizations and will require the ability to flag, at transaction level, whether the counterparty to a trade meets the definition of a “customer” as defined in the rule

Counterparty static reference data is an area most organizations struggle with due to fragmented systems – these issues may be exacerbated for this metric if a specific counterparty qualifies as a customer under some circumstances, but not others

Legend:

Minimal Effort

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Moderate Effort

Significant Effort

New Metric

Signifies the level of investment or effort required to implement and report the required metric

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Sia Partners – Volcker Credentials

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Sia Partners – Volcker Credentials Sia Partners US has a specialized practice offering Dodd-Frank Act (DFA) professional services • Participation in: • Seminars

Following Developments

• Webinars • Conferences

• Communication with a wide network of industry-renowned specialists on the regulation

• Volcker Rule Compliance Program

Publishing Newsletters & Documentation

• Volcker Rule Enhanced Reporting Requirements • Swaps and DFA Title VII, including Extraterritorial Application of Title VII Swap Provisions • European Market Infrastructure Regulation (EMIR) • Comparison with European Regulation

• Advisor to international clients on the latest rules and deadlines, along with the corresponding potential

DFA Advisory

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impacts to their business (see details in next pages) • Implementation Program of the Dodd Frank Act, including the final Volcker Rule, at a global French Bank • Implementation of the Volcker Compliance Program of a US Regional Bank • Implementation of the Volcker Compliance Program of the NY Branch activities of a French Bank • Impact Analysis of the DFA on the organizational structure of the US Activities of a French CIB • Impact Analysis of the Volcker Rule on trading and investment activities of a large international Bank 10

Sia Partners – Volcker Credentials Major global French Bank Context

Sia Partners approach

• The Wall Street Reform and Consumer Protection Act (a.k.a. Dodd Frank Act, DFA) was

• Strong cooperation with Legal, Compliance, Business and ITO in New-York,

signed into law in July 2010 in response to the failures that led to the financial crisis.

• NARRI (North American Regulatory Response Initiative) implementation project, led from

New-York, coordinates the workstreams relative to each high-level requirement with relays, notably in Paris, to cover worldwide locations.

Paris Head Office and in locations • Participation in various project workstreams • Regulatory watch and analysis (Federal register, CFTC no-action letters, Law

firms analyses) In order to produce the following deliverables:

Objectives • Monitor

• Impacts assessment: Rules Summaries / Impact Assessment Memos,

communication to Management and worldwide locations

and analyze regulatory updates (Volcker, Title VII, Push-Out, FCM requirements...) with Legal and Compliance

• Worldwide implementation progress and costs follow-up • Compliance plan elaboration & implementation: Steering Committees /

• Assist Business (Fixed Income and Equity & Commodity Derivatives), Legal and

Compliance Plans (synthesis of requirements and implementation) / Training Material / Policies & Procedures

Compliance in assessing Volcker proprietary trading and covered funds prohibitions impact on business (Review of the desks and exemptions that may apply; List of covered funds; Development of a conformance plan for the prohibited activities. Analyze Trading Metrics requirements, define calculation assumptions (consistently with the Industry) and write business requirements. Analyze Enhanced Compliance Program requirements and determine scope of requirements • Elaborate Title VII compliance plan for CIB Business lines Fixed Income, ALM-Treasury,

and Equity & Commodity Derivatives, in liaison with Legal, Compliance, Business and Operations, covering External Business Conduct (pre-trade disclosures, daily mark communication…), Reporting, Recordkeeping, Clearing and SEFs. Lead the implementation of changes to existing systems; Train F/O people (Marketers, Traders); Identify Key Performance Indicators for ongoing compliance monitoring • Perform Dodd-Frank impacts assessment for Securities Services U.S. activities (Custody,

Clearing, Asset & Fund Services, Securities Lending, Forex) and implement compliance plan (project management, coordination and follow up) • Analyze Swap AP Supervision requirements & Assist HR in implementing pre-employment

background checks in all countries: project management, coordination and follow-up • Analyze the requirements of the Enhanced Customer Protections Rule for FCMs.

Facilitate compliance with the requirements to create and publish disclosures (Risk, Financial information) and develop plans for a Risk Management Program

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Key points • Large structured program with 1 workstream by regulatory requirement,

numerous stakeholders within support functions and business • Interpretation of long and complex rules and clarification of business impact

so as to facilitate Management decision-taking and ITO/Business Management operational implementation • Project driven by regulatory reform requirements and schedule

• Intervention in both New York (between 3 and 6 consultants) and Paris (1

consultant) for 2 years

Sia Partners added value • Regulatory and business knowledge of capital market and in particular

derivative activity • Dedicated working group within Sia Partners to monitor / decrypt regulatory

issues (EMIR/MIFIR/MAD, Dodd Frank, etc.)

• Good understanding of the Bank organization • Ability to work in an international environment • Proven methodological skills in matters of project management

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Sia Partners – Volcker Credentials US Regional Bank Context

Sia Partners approach

• On December 10, 2013, U.S. Regulators released the Final Volcker Rule

• Strong cooperation with Legal, Compliance, Business, Risk and

• The bank and all of its subsidiaries are subject to the following provisions of the Volcker

Rule: • A ban on proprietary trading activities, • Restrictions in investments and sponsorship of certain private equity funds and

hedge funds, that fall under the definition of “covered funds”, • A requirement to establish a compliance program, including enhanced compliance obligations and reporting of trading metrics.

• In this context, the bank has asked Sia Partners to assist in the development of a compliance program to comply with the Volcker Rule.

Objectives • Review the initial assessment of trading and investment activities that are impacted by

the restrictions of the Rule, and assist in getting validation of this assessment from Senior Management

Operations, • Collective sessions with stakeholders to review and validate

initial assessment of the activities impacted by the Rule, • Interviews and dedicated workshops to collect information

about the current situation (compliance framework; existing policies, procedures and controls; Risk and P&L indicators; existing systems), • In-depth analysis of the requirements of the Rule, • Organization of various project work streams (“Gap Analysis & Roadmap” and “Metrics Reporting”) In order to produce the following deliverables: • Impact assessment • Compliance framework gap analysis and roadmap • Trading metrics business requirements

• Produce a gap analysis between the existing compliance framework at the bank and the

enhanced compliance obligations required by the Rule, and deliver an implementation roadmap: • Determine a list of required Policies and Procedures • Inventory existing Policies and Procedures & perform a gap analysis • Draw documentation plan • Determine limits and controls • Establish Management Framework • Define training approach • Define testing strategy • Determine record retention requirements • Determine roles & responsibilities around metrics production • Write trading metrics reporting business requirements: • Define calculation assumptions for the 7 metrics required by the Volcker Rule • Write business requirements accordingly, in order to specify to IT the

Key points • Interpretation of long and complex requirements and

clarification so as to facilitate Management decision-making and operational implementation • Quick integration of Sia Partners consultants within the bank • Intervention in San Francisco

Sia Partners added value • Regulatory and business knowledge of capital market and retail

banking activities • Dedicated working group within Sia Partners to monitor /

decrypt regulatory issues (Volcker, Dodd Frank Title VII, etc.)

• Proven methodological skills in matters of project management

requirements that need to be developed and implemented

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Sia Partners – Volcker Credentials New York Branch of a major global French Bank Context

The Sia Partners approach

•

• Advisory Support • Contributes

The Volcker Rule and the Dodd-Frank Act’s regulatory requirements, put more emphasis on financial institutions to provide more detailed permanent control reporting.

•

Banking entities regulated by the Volcker Rule are currently in a conformance period and attempting to ensure activities are in compliance with the final rule.

•

The NY Branch is a smaller entity with regards to its treatment under the Volcker Rule’s tiered compliance approach.

Nonetheless, the NY Branch operations involve the use of a number of instruments and strategies which lead to a substantial compliance burden under the Final Rule.

to the development of a good-faith compliance approach during the conformance period as outlined in the Volcker Rule.

• Analyze existing controls, reporting, and P&P in order to determine gaps in reporting as required by regulators.

• Draft P&P as a component of a larger Volcker Rule Compliance program.

• Develop and implement adequate monitoring solutions as stipulated in P&P.

Objectives

Key points

• Assess and develop strategies to ensure Volcker Rule compliance

• From a compliance stand point, it is necessary to develop and

by working closely with Risk.

• Assess CLO positions for compliance and determine if and how • • • •

said funds can be held by the banking entity.

Design a compliance program and associated policies and procedures.

Develop and document monitoring and testing strategies.

Identify opportunities for the automation of Volcker Rule Compliance monitoring and reporting.

Assess derivative positions for compliance and develop tests to demonstrate that activities are not considered proprietary trading.

demonstrate a culture of good-faith compliance to regulators through the use of policies and procedures outlining monitoring, reporting, and internal controls.

Sia Partners added Value • Extensive knowledge of financial products and their treatment

under the Volcker Rule • An in-depth understanding of the challenges faced by our clients

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Sia Partners – Volcker Credentials New York Operations of a top 3 French Corporate and Investment Bank Context

The Sia Partners Approach

• 2 consultants in NY for 1 year

• Prepared an impact analysis based upon likely outcomes (DFA

• The New York operation of a global French bank • Sia Partners US was engaged to: • Perform an Impact Analysis of the Dodd-Frank Act (DFA) on

the organizational structure of the US Activities of the bank.

• Develop a DFA Project Portfolio.

Study).

• Trained 160 members of the global staff on DFA. • Developed a list of tasks that would need to be implemented to

ensure timely compliance with DFA. • Consolidated the anticipated tasks into 20 projects along with

budgets by functional area.

Objectives • Given the Bank’s large capital markets business, Sia Partners US’

focus was on:  The implications of Title VII for its global swaps activities,

Key points • Impact analysis , training and DFA project portfolio all produced.

namely registration, pushout of swaps from the New York Branch, clearing of clearable and handling of uncleared swaps, margins / collateral requirements, use of swap execution facilities, classification of clients, portfolio compression, reporting and recordkeeping, among others.  Volcker Rule, notably the permissibility of activities, stakes in

funds, compliance program and the 17 risk metrics / indicators.  Prudential controls, resolution plan, Whistleblowing, and

compensation aspects (clawbacks).

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Sia Partners added value • Technical DFA expertise to help identify actions to respond to DFA. • Project management skills to keep the project on schedule.

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Sia Partners – Volcker Credentials New York Operations of a top International Bank Scope

Deliverables

• Impact Analysis of the Dodd-Frank Act (DFA) Volcker Rule on

trading and investment activities.

• New Investment Policy describing how activities are managed to

comply with the Volcker Rule.

• Critique of other policies enforced.

Client

Resources

• New York Operations of a top International Bank

Focus

• 3 Consultants in New York

Sia Partners added Value

• Given the Bank’s activities in New York , Sia Partners’ focus is on: 



Evaluating Investment Portfolio Policy and practices to determine their treatment under the draft Volcker Rule.

• Extensive knowledge of Regulatory and Compliance.

• An in-depth understanding of the challenges faced by our clients

from both regulatory and business–specific perspectives

Understanding the interaction with other aspects of the trading activities, such as accounting, liquidity and valuation, and propose solutions to integrate these in the investment policy while ensuring compliance with the Volcker Rule.

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Sia Partners Presentation

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An introduction to Sia Partners

A consulting team with global reach

A vertical approach...

• • • • •

Financial Services Energy & Utilities Telecoms & Media Transportation & Logistics Manufacturing

… from strategy to operations

• 570 consultants

• Established in 1999

• 15 offices

• 110 M$ revenue

• • • • •

Operational strategy Business Management PMO / Business analysis IT Strategy & Architecture Change management

Sia Partners is independent from IT companies and financial audit firms Our project culture is strongly oriented towards expertise and delivering results

We have a global reach with integrated teams based in financial centers across US, Europe and Asia

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Fact Sheet Key Figures

88 M€ Revenues

1999 Creation date

15 Offices HQ : Paris

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Sia Partners is a unique management consulting firm composed of passionate consultants who are able to drive business changes among our customers.

Through unparalleled industry expertise, we are delivering superior value and tangible results for our clients.

Sia Partners is run by an international management team and organized as a partnership.

Our client portfolio

150+

6,000

20%

Clients

Assignments since its creation

of Fortune 500

15%

70%

15%

Strategy

Business Transformation

IT & Digital Strategy

Our services

Partners

22% Of growth during the economic crisis

#17 in Vault Top 25 Consulting Europe list

18,500 Followers on LinkedIn

40 Exclusive Surveys each year

300,000 visitors on our blogs per year

Our team

550+

25+

10

Consultants

Nationalities

Sector teams and 10 Service teams

Training sessions a year

81% Of our consultants defines Sia Partners as a best place to work for

35 Internal mobilities each year

Actuarial Services CFO Advisory Change Management CIO Advisory Corporate Strategy CRM & Marketing Digital transformation Human Resources Operational Excellence Procurement & Sourcing

A best practice in Corporate Social Responsibility Sia Partners has placed employee commitment at the heart of its HR strategy.

We consider our team with respect and fairness and help them developing their value and skills. We promote and value a healthy balance between job responsibilities and family life for all employees. We also make sure that our offices are environmentally friendly. Sia Partners has made responsibility to society an integral part of its action. The firm is a member of several networks of corporate decision makers as well as trade associations.

Our recruitment plan for 2015

25

10

85

End of studies interns

VIE

Graduates

2 Student Contests

12 Career fairs In France

8000 Applications received each year

Our expertise Banking Consumer Goods & Retail Energy, Resources & Utilities Government Healthcare Insurance Manufacturing Pharmaceutics Telecommunications & Media Transportation & Logistics

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Our recruitment process HR Motivation English test

Consultant

Manager

Business Case

Expertise

Partner

* Only 3 steps for an internship

How to apply for a position You can find our job opportunities on our career pages on LinkedIn and Job Teaser.

You can also send us a spontaneous application at recruitment@siapartners.com (please specify the expertise you apply for)

Sharing knowledge & insights Sia Partners has developed since 2002 a policy of research and publication.

Our teams decode weak and strong signals in the news, meet with various experts, carry out quantitative or prospective studies, etc. It gives us a strong knowledge of the needs of our clients and allows us to better anticipate their future needs.

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Paris | Lyon | Londres | Amsterdam | Brussels | Rome | Milan | Casablanca| Dubaï | Abu Dhabi | Riyad | New York | Montreal | Hong- Kong | Singapore

For more information, visit : www.sia-partners.com Follow us on LinkedIn and Twitter @SiaPartners

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Our Financial Services Offers Our domain focus

Main transformational offerings

Retail Banking & Specialized financial services Business

Asset management & Securities Investment banking & Commercial banking Insurance services

Support

Finance & Risk management Human resources

• Regulatory compliance and financial performance • Basel II & III, MiFID, Solvency II, T2S, FATCA, Dodd Frank • Internal control, Anti-money-laundering, KYC • ALM, financial management and efficiency • Regulatory reviews, data architecture, operating model • Design and launch of new offers • Mobile banking, multi-access-oriented products • Derivatives, Private banking, Micro-finance

Leading companies trust us with key assignments...

• Banking and insurance convergence • Performance optimization • Productivity and operational efficiency plans • Process improvement, Lean Six-Sigma, DILO • Front-to-Back optimization • Domestic and international growth

• Support for subsidiaries management and organization • Operational due diligence, post-merger integration • Location strategy, BPO captive health check CONFIDENTIAL © Sia Partners

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Research, publication and debates An active policy of research and publication

A strong contribution to marketplace debate

Original research

Conferences, seminars and training

We proactively publish thought leadership with comment and analysis on current topics impacting our clients as well as strategic trends. Our publications include market insights, opinion columns, benchmarks and strategic marketing studies.

Sia Partners actively participates in marketplace debates and reflexions, with experts speaking at numerous conferences and managing professional training sessions throughout the year.

Think tanks Sia Partners is a member of several corporate networks of decision makers, as well as specialist associations promoting Green Deal business or financial services.

Press articles More than 100 press articles per year, opinion columns and strategic studies that are often quoted in business oriented –as well as mainstream– press and TV ; we also feed news agencies (AFP, Reuters) on hot topics.

Expert newsletters & studies from our competence centres Our practices regularly publish newsletters and research studies drawing on industry data, detailed desk research augmented by the additional insight of our sector experts. > More than 15 exclusive studies per year CONFIDENTIAL Š Sia Partners

Sia Partners Financial Services Blog: http://en.finance.sia-partners.com/ 20

About Sia Partners US Our expertise Sia Partners in the Americas has been rapidly enlarging its client portfolio - up to 15 - and forecasts more than $10M revenues over the next 12 months Over 50 consultants deployed in North America, With approximately 10 consultants covering Canada.

Financial institutions, covering regulatory framework and response initiatives, business transformations, and Compliance and IT control solutions. Over the past two years, we have been mainly providing Corporate & Investment Banking and Asset Management services on hot topics such as the Dodd Frank Act including the Volcker Rule, the Enhanced Prudential Standards, CCAR, FATCA, and AML, and now we are also servicing the retail banking sector.

Client Collaboration

Key Competencies

Sia Partners works with leading global banks and financial institutions.

Our sector-targeted approach and global delivery capabilities are tailored to help manage risk, transform business performance, respond to new business requirements, and sustain improvement.

CORPORATE & INVESTMENT BANKING FINANCIAL SERVICES STOCK EXCHANGES BROKER-DEALERS ASSET MANAGEMENT RETAIL BANKING WEALTH MANAGEMENT

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Our areas of focused project work include the following services:  Dodd-Frank, CCAR, Volcker Rule, Federal Reserve Enhanced Prudential Standards: Impact analysis & Implementation  Policies & Procedures Development  Risk Management & Control: Market, Credit, Operational, IT Risk  IT Risk Assessments  Regulatory & Compliance  Project Management / Business Analysis  Internal Audit & Control  Quantitative Advisory Services  Industry Training 21

Our Value Proposition

Flexible & Responsive

We work with clients on a project and/or loan staff basis with minimal complexity and hassle.

We strive to find the right commercial arrangement that works for each client.

Absence of unnecessary overhead allows us to be very responsive to client needs.

Expertise Led

Cost Effective

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Complex problems require specialists with deep knowledge and hands on experience.

In our focus areas, we have staff and access to a network of subject matter specialists who can bring the needed skills and expertise.

Our specialists play a “hands-on” role on our projects – we don’t sprinkle their time in among a team of generalists.

Our focus and absence of unnecessary overhead enables us to offer a very competitive rate structure.

We are focused on building long-term relationships and are willing to invest time and resources to demonstrate our commitment.

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Breadth of Our Service Offerings The versatility of our project capabilities Business analysis of inherent risks and internal controls, assessing to ensure proper performance, oversight and documented results Regulations-focused assignments: Dodd-Frank Act analyses, FFIEC compliance, International Financial Reporting Standards (IFRS), US GAAP, Basel II, Basel III, CCAR, Federal Reserve Enhanced Prudential Standards, Anti-Money Laundering (AML), FATCA, Market Abuse Directive Development of risk policies and manuals including market, credit, IT and operational risk Analysis of complex instruments and their investment risk, from equity and derivative products spanning from commodities to Forex, over the entire trade lifecycle Strategic consulting projects: creating strategic global plans involving business process reengineering Organizational processes (front to back office, accounting, internal controls, management controls, process mapping, business process reengineering)

Database and data reference projects: repositories of market data, instruments, financial products, clients, thirdparties CONFIDENTIAL Š Sia Partners

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Asia

Belgium

Canada

France

Italy

Singapore 55 Market St, Level 10 Singapore, 048941 T. +65 6521 3186 Hong Kong 701, 77 Wing Lok St, Sheung Wan, HK T. +852 3975 5611

Brussels Av Henri Jasparlaan, 128 1060 Brussels - Belgium T. +32 2 213 82 85

Montréal 600 de Maisonneuve Blvd. West, Suite 2200 Montreal, QC H3A 3J2

Paris 18 bd Montmartre 75009 Paris T. +33 1 42 77 76 17 Lyon Tour Oxygène, 10-12 bd Vivier Merle 69003 Lyon

Rome Via Quattro Fontane 116 00184 Roma T. +39 06 48 28 506 Milan Via Medici 15 20123 Milano T. +39 02 89 09 39 45

Morocco

Netherlands

Middle East

UK

US

Casablanca 14, avenue Mers Sultan 20500 Casablanca, Maroc T. +212 522 49 24 80

Amsterdam Barbara Strozzilaan 101 1083 HN Amsterdam T. +31 20 240 22 05

Dubaï, Riyadh & Abu Dhabi PO Box 502665 Shatha Tower office 2115 Dubai Media City Dubai, U.A.E. T. +971 4 443 1613

London Princess House, 4th Floor, 27 Bush Lane, London, EC4R 0AA T. +44 20 7933 9333

New York 115 Broadway 12th Floor New York, NY10006 - USA T. +1 646 496 0160

For more information, visit : www.sia-partners.com Follow us on LinkedIn and Twitter

@SiaPartners

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