It is my pleasure to appear here today on behalf of the French Banking Association and to inform you of the current status of the efforts of our Association, and indeed the entire financial community in France, to address on a thorough, global, and transparent basis all issues remaining from the Holocaust in France and to ensure that all remaining funds taken from victims of that period are returned to them or their heirs.

I want to thank you, Chairman Leach, for your leadership and dedication concerning this important subject matter not just this year, but over the last several years. You have discharged your public duties in a most admirable and responsible manner.

Working very closely with the French government, and with the complete support of the Jewish communities in France, the French banking community is making every effort to address its role in this terrible chapter of our nation’s past, and to seek redress for any and all remaining victims of that period, or their heirs. The French banks recognize, and have publicly acknowledged, that an enormous injustice was done during the Occupation of our country and are determined to address all remaining vestiges of that period. To that end, we have embarked upon an enormous logistical undertaking that requires the good will and good faith of interested individuals everywhere in order to complete its objective. My purpose today is to explain to you what we have done and are continuing to do, and to ask your help in working with us to achieve the goals that I am sure we all share.

Let me begin by giving you a very brief history of the French experience during the Occupation, and in particular the role played by French banks during that period. This history is important: Every country in Europe encountered a different experience with respect to the rise of Nazi Germany and the Occupation of much of Europe; the French experience was in many critical respects very different from the experience of banks in Switzerland and other countries.

To begin, in June 1940 the North of France was forcibly occupied by the German army, which immediately took and exercised firm control over virtually all financial activity in France, specifically including the banks which were immediately put under military authority. For approximately two and one-half years thereafter, the southern part of our country was nominally administered by the so-called Vichy regime, but as a practical matter French institutions in neither the north nor the south had significant freedom from German policies. As a result, throughout the Occupation and until the Liberation of France in August 1944, every financial institution in France operated under legislation and administrative decrees that were undeniably discriminatory and anti-Semitic. These included the infamous "billion franc fine" imposed by the German occupying authorities in December 1941 on the Jewish community and paid to the German state with the money taken from the accounts of Jewish account holders. On a more day-to-day basis, the securities and banking accounts, as well as the safe deposit boxes, of Jewish depositors were systematically frozen and often seized on the basis of increasingly severe anti-Semitic legislation. There is no denying the appalling quality of those atrocities or the fact that they were accomplished at the specific direction of the organs of the French State. As our president, Jacques Chirac, made clear in his famous speech of June 16, 1995, we must never forget the debt that we owe to victims of the Holocaust in France.

The situation in France thus differed from that of Switzerland, among other countries, primarily because the discriminatory acts of the period were accomplished by governmental organs under control of Nazi Germany, which imposed these vicious views on the banks of France through administrative edict.

The experience in France immediately after the War was also very distinctive. Immediately upon the Liberation of France in August 1944, the Provisional French Government and the successive governments of the Fourth Republic enacted comprehensive legislation designed to identify all victims of discriminatory acts during the Occupation, and to provide a process whereby all such victims could obtain — with interest — any and all funds or securities that had been taken from them during the Occupation. That legislation was carefully considered, was universal in its application, and was effectively implemented by the French courts and the French administrative agencies. A complete accounting of the efficacy of those efforts must await the completion of the historical studies now being conducted by the Mattéoli Commission — of which I will speak shortly, and on which I understand members of the Commission are also here to speak to you today. But based upon the preliminary reports of the Mattéoli Commission, it appears that a very large majority of all of the victims of the Holocaust in France whose funds, securities, or assets were frozen or taken by any French financial institution during the Occupation obtained restitution or compensation during this immediate post-War period. I believe that the comprehensiveness of this legislative program, and the good faith of its implementation, has not been fully understood or appreciated in this country.

The fact remains, of course, that not every victim of the Holocaust in France obtained restitution immediately after Liberation: It is certain that many individuals were unable to pursue their remedies at that time. We do not yet know the number or even the percentage of individuals who did not benefit from those comprehensive measures. But if even one such victim was deprived of his or her just compensation, of course, that situation merits our attention. And it is to the identification of all such remaining uncompensated victims of the Holocaust in France to which the French Banking Association and the financial communities in France as a whole have directed their attention. So let me now turn to the efforts that have been underway for some time, and give you a report on their current status.

3. Current Activities in France

Encouraged by President Chirac’s unambiguous commitment to bring all remaining issues relating to the Holocaust in France to light, the French government has sponsored a number of different initiatives to pursue that goal. Among them, the most significant with respect to the French banking industry was the appointment in January 1997 — almost a year, I should add, before the first American private litigation was brought against any French bank relating to these issues — of the Mattéoli Commission. The Mattéoli Commission is a blue-ribbon panel, whose members have been appointed in close consultation with the French Jewish community, which was charged by the Prime Minister with making every possible effort to uncover all remaining aspects of the Holocaust in France, to identify any remaining funds, securities or property that had not been returned to the rightful owner, and to propose a means of appropriate restitution. Again acting with the full consultation and support of the French Jewish community, the Commission has hired a number of historians, auditors, and other professionals to help them with that task. In March 1998, and acting at the specific recommendation of the Mattéoli Commission, the Prime Minister announced the formation of a special committee, headed by Jean Saint-Geours, that has been given the specific task of coordinating activities in the French Banking sector in their efforts to work with the Mattéoli Commission. And I am pleased to state that last week Prime Minister Jospin has formally announced the formation of a committee, headed by former Supreme Court Justice Pierre Drai, to provide an effective administrative remedy whereby all victims of the Holocaust in France, wherever they are located, will obtain complete restitution of any funds or assets taken from them.

Let me now turn to the efforts that the various French banks and other financial institutions have made in coordination with the Mattéoli Commission to address this history. The French Banking Association itself comprises more than 100 banks that were doing business in France during the Occupation. In addition, there are a number of financial institutions — often very significant ones — that also took deposits during that period, but are not technically "banks" under our law. These include, for example, public institutions such as the Caisse d’Epargne, which is the French national savings institution, and the Post Office, which in France today as well as during the War opened accounts for depositors.

The principal and overwhelming task confronting the French banks has been to identify, locate, and correlate the records necessary to address this history. This task is immensely complex for two principal reasons. First, many of the events during the War that caused such tragic harm to its victims involved the operations of different organs of the French government. An official organization called the Caisse des Dépôts, for example, was the principal conduit through which frozen and expropriated funds were typically transferred to Germany during the Occupation. The records of the Caisse des Dépôts, as well as those in the National Archives and many other French governmental institutions, were thus centrally necessary to a global and comprehensive explanation of this history; the records of the banks alone do not reveal this history. Second, any funds or securities that remained unclaimed at the end of the Occupation for thirty years automatically became the property of the French State under French law of escheat, and were generally transferred to the French treasury. Moreover, the record keeping obligations of the French banks ceased ten years after any such escheat occurred, with the result that — generally speaking — many records that may have been held by the French banks at the end of the War were no longer in their possession approximately forty years later except by chance.

As a result of these complexities, and particularly because of the unusual role played by governmental entities during the Occupation, the principal activity of the Mattéoli Commission and the other groups working with it has been to focus on the location, coordination, and ultimately the reconciliation of documents found in many different locations. This process has been massive indeed, and has involved the effort of well over two hundred professionals. I am happy to say that the French Banking Association has played a major role in working with larger French banks to develop the most effective procedures for compiling this historical research, and I believe that we contributed to the Research Manual on this subject published by the Mattéoli Commission earlier this year.

As a result of these efforts, all of the banks that are members of the French Banking Association — and, I believe, other financial institutions in France as well — have now completed the research that is possible based upon the remaining documentation available to them and will formally submit the fruits of this research to the Mattéoli Commission at the end of this month. It is our hope and understanding that the Mattéoli Commission will be in a position at or near the end of 1999 to announce the results of this massive research, in line with the directive of Prime Minister Jospin, who demanded such a time table at a well-received speech given to the largest Jewish organization in France in October 1998.

All of the banks in France have formally and publicly pledged to continue to work with the Mattéoli Commission until all possible research into the fate of victims of the Holocaust in France and the fate of their assets in French banks has been completed, and the facts of that period are brought to light. We are also committed to working closely and cooperatively with the commission to be chaired by Pierre Drai that will provide an administrative remedy for the restitution of all unreturned funds or other assets seized or taken in France during the Occupation. And finally, the constituent banks of the French Banking Association have formally pledged to make a significant contribution to the Holocaust Fund announced by Prime Minister Jospin. That contribution, we believe, can appropriately be made only when the historical analysis being pursued by the Mattéoli Commission has been substantially completed and made public. In March 1999, the French Banking Association, speaking on behalf of all French banks that had done business during the Occupation, formally stated these commitments in a declaration that I will attach to the written copy of my remarks — a declaration that was positively received by the Jewish communities in France. I can assure you that these commitments are sincere, and that the Association and its constituent banks will follow through with them.

I am very happy to answer any specific questions you may have about the activities of the French Banking Association, and of its constituent banks, with respect to these immensely serious and important activities. Before doing so, let me again emphasize the significance of these activities and address some of the issues that I know may be on your mind.

First and foremost, let me emphasize to you the utter good faith with which these activities are being pursued by my organization and its constituent banks. As enunciated by our President and our Prime Minister, it is a matter of fundamental and imperative French policy to get to the bottom of all remaining issues from the Holocaust in France, and to devise a universal, effective, and transparent program for restitution. The French Banking Association and its constituent banks completely support that policy, without reservation, and are committed to its success.

Second, the task upon which we have embarked is a daunting one. For reasons I have briefly summarized, the records remaining from the Occupation are fragmentary and dispersed, and locating and reconciling them involves cooperation among many different organizations, notably those that are part of the French government. The French banks do not have "lists" that they are hiding; it is not simply a question of "pushing a button" to identify victims of that period, or the degree to which they have or have not been compensated to date. Those facts can only be determined through hard work, through cooperation with many different organizations, and through time. Fortunately, much of that work is behind us, and we are confident of ultimate success.

Third, the fruits of this progress will be global and transparent. It is the specific mandate of the Mattéoli Commission that all victims of the Holocaust in France be given all extant information concerning their assets during the War, and appropriate restitution to the extent that they have not already received it. Thus, our efforts are not limited to victims or their descendants living in France, but will be made available to such individuals worldwide, wherever they now live.

Fourth, we believe this has been and should remain an inclusive process. The Mattéoli Commission was established in very close coordination with the Jewish community in France, and my organization has kept that community regularly informed of our progress, and of our plans. We believe we have the support of that community, and are committed to working with them until justice is done. It is for that reason that we ask you to support us as we continue to try to make our efforts as comprehensive, as global, and as transparent as humanly possible. For the moment, the focus of those activities necessarily must be in France: It is in France that the relevant documents are located, and it is the French government that uniquely has access to records necessary to learn our history and how best to address it. I am confident that the Mattéoli Commission and the French government will share the results of this information with the worldwide community of individuals with interest in this issue. There may be individuals and organizations who, at that time, will not be satisfied by those results. But until those results are known, we strongly believe that the efforts that are underway in France deserve support, and that the participants in this process have earned the right to your trust. I hope we all agree on the common goal, which is to mark this generation as the last one in history in which doubts or uncertainties remain about the fate of victims of the Holocaust in Europe, or in which any victims of that period remain uncompensated. It would be a tragedy if bickering or indecisiveness about the most appropriate means of achieving that goal were to hamper the major strides we have made to reach them.

Attachment March 24, 1999

The French banking community today announced a comprehensive set of measures providing for full restitution of dormant assets which may be in the banks’ possession and which belonged to Holocaust victims of all nationalities. The measures were adopted by the Executive Council of the French Bankers Association in the name of the 106 French banks which were either in existence in France during the Nazi Occupation or which acquired banks then active. The measures include, very importantly, a formal acknowledgment of the French banks’ moral debt to the Jewish community for their involvement in acts of confiscation carried out during the Occupation.

"The Holocaust was the most tragic and devastating event of the 20^th century" said a spokesman for the French banks. "The consequences of this tragedy have still not been fully resolved. Although today’s generation cannot be held responsible, it is still our duty to ensure that justice be served for Holocaust victims and their families. Beyond this duty of serving justice, we also bear the responsibility of perpetuating the memory of these tragic events, so that the awareness of future generations will prevent the occurrence of similar atrocities."

As a result of the anti-Semitic laws enacted by the Nazis and by the Vichy government, the banks, as well as other institutions, were among the cogs in the terrible machine of confiscation of Jewish assets in France. They therefore bear a duty of reparation towards the victims of these laws.

As leaders of important French economic institutions, the banks’ officers share the views articulated in the name of the French nation by President Jacques Chirac in his speech of July 1995, and they express their profound solidarity with the victims of the anti-Semitic laws in force during the Occupation, and their families.

The measures announced today address the concerns regarding bank assets expressed by leaders of the Jewish community in France, and by other interested organizations around the world, and they create the appropriate framework for a just, complete and transparent resolution of all the issues remaining from this tragic period.

In its Second Progress Report, the Mattéoli Commission estimates that approximately FRF 333 million in cash and FRF 2 billion in securities deposited with French credit institutions were frozen and confiscated by the Vichy and German authorities during the Occupation (1940-1944). Assets of approximately FRF 2.4 billion (comprising principal and interest) were restored to their rightful owners after the Liberation (1944-1954) under indemnification laws. These figures are in French francs of the relevant period. However, the Report also shows that because so many perished or were dispersed as a result of Nazi persecution, there remain assets in accounts and safe deposit boxes that have not been returned to their rightful owners. That is why the current systematic research into the dormant accounts must be completed.

The Executive Council of the French Bankers Association has thus adopted the following measures:

These initiatives will be implemented within the context of the comprehensive research efforts now underway in France under the leadership of the Mattéoli Commission. A significant amount of information has already been submitted by the banks to the Mattéoli Commission, which is reflected in the Commission’s Second Progress Report published in February 1999. The banks are committed to completing their archival research as quickly as possible, and to communicating the results by September 15, 1999 at the latest.

The French banks strongly believe that the measures announced today provide the framework guaranteeing the complete and equitable resolution of both the historical and the moral aspects of the confiscation of bank assets held in France by persons considered to be Jewish under the discriminatory legislation of the Nazi and Vichy regimes.

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Robert de Bruin Michael Freitag or Jason Lynch

French Bankers Association Kekst and Company

(33.1) 48.00.50.01 (1) 212.521.4800