The wealth management consulting market in France is undergoing a phase of reorganization. The boundaries between private banking, wealth management, and everyday banking services are blurring due to European regulations and new distribution models. In this context, players like Propatrimonia are seeking to combine wealth management advice with banking functionalities within a unified offering.
Bank-as-a-Service and Wealth Management: An Expanding Model
Most content dealing with financial optimization focuses on internal cash management or reporting tools. They overlook a fundamental trend: the possibility for a wealth management firm to distribute banking services without becoming a credit institution itself.
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This model relies on Bank-as-a-Service. Specifically, licensed providers (Treezor, Swan, Solaris, Banque Wormser, among others) supply technical components, payment accounts, cards, automated transfers, which non-banking entities integrate under their own brand. The ACPR classifies these arrangements as white-label banking services and regulates their outsourcing through updated guidelines in 2023.
For a player like Propatrimonia, the interest is twofold. Offering its clients banking functionalities (sub-accounts by wealth project, virtual cards, flow management) while maintaining control over advice in taxation, transmission, or life insurance. The client, in turn, accesses a single entry point instead of juggling between their retail bank and their wealth management advisor.
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In practice, those wishing to explore this integration logic can turn to Propatrimonia’s banking solutions, which illustrate this convergence between wealth support and banking services.
Open Finance and PSD3 Regulation: What Changes for Wealth Management
Competing articles frequently mention banking communication and account aggregation. They do not mention the upcoming European framework, which goes far beyond simple aggregation.
The European Commission has presented a proposal for a PSR regulation and PSD3 directive, accompanied by the FIDA project (Financial Data Access). The goal is to extend the principle of open finance to products like life insurance, retirement contracts, or investment portfolios, and not just to payment accounts.
What FIDA Could Change in Practice
If the text is adopted in its current form, a wealth management advisor could, with the explicit consent of the client, access all of their financial data scattered across multiple institutions. This includes life insurance contracts, securities accounts, and retirement savings products.
- Wealth consolidation would become automated: no need to manually request statements from each bank or insurer to create a complete wealth overview.
- Taxation or transmission recommendations would gain precision, as the advisor would have a comprehensive and updated view of the client’s assets.
- The choice between multiple contracts or investment vehicles could rely on objective comparisons, fueled by real and not just declared data.
The available data does not yet allow for conclusions about the adoption timeline or the final scope of the text. However, the regulatory direction is clear: financial data is circulating more and more, and players who prepare for it have a structural advantage.
Limits and Gray Areas of Integrated Banking Offers in Wealth Management
The integration of banking and wealth management is not without friction. Several points deserve a clear examination before considering this type of solution as a universal answer.
Potential Conflict of Interest Between Advice and Distribution
When the same entity recommends a wealth strategy and distributes the associated banking products, the question of the independence of the advice arises. The status of financial investment advisor (CIF) imposes transparency obligations regarding the compensation received, but the client must verify whether the advice remains independent or is linked to distribution. This distinction, rarely highlighted in marketing brochures, conditions the quality of the support.
Deposit Protection and Legal Nature of Accounts
In a Bank-as-a-Service model, the client’s funds are held by the licensed institution (the partner bank), not by the consulting firm. Therefore, the deposit guarantee mechanism applies at the level of the partner bank. The client has an interest in precisely identifying which institution holds their funds and what level of protection results from it.
Taxation and Transmission: Banking Does Not Replace Tailored Advice
Having a bank account integrated into a wealth platform does not automatically simplify tax arbitrations. Issues of transmission, dismemberment, or optimization of real estate wealth tax require individualized analysis that banking tools alone cannot provide. The added value lies in the articulation between banking service (execution, flow management) and wealth advice (strategy, measurement of tax impact).
Concrete Criteria for Evaluating a Wealth Banking Offer
Before subscribing to an offer that combines banking services and wealth advice, several verification points allow for distinguishing a structured solution from mere marketing packaging.
- Identify the regulatory status of each participant: is the consulting firm a CIF, an insurance broker, or both? Is the partner bank licensed by the ACPR?
- Check the transparency of fees: are commissions on life insurance contracts or investment products distinct from regular banking fees?
- Examine interoperability: do the banking account data actually feed into the wealth overview, or are there two separate interfaces under the same brand?
- Request the data retention policy and the consent framework applied, especially in anticipation of FIDA obligations.
These verifications do not guarantee the performance of a wealth strategy. However, they do allow for assessing the robustness of the proposed system and differentiating an integrated offer from a mere aggregation of services.
The convergence between banking and wealth management is not a passing phenomenon. European regulation is pushing in this direction, and distribution models are evolving accordingly. For the saver, the choice criterion remains the same as in traditional private banking: the quality of advice, the transparency of fees, and the robustness of the regulatory framework that protects their assets.