Wed, Mar 4, 2015
The EBA has today (4 March 2015), published its CRDIV Remuneration Guideline Consultation. The consultation period runs until 4 June 2015.
We strongly advise all firms to engage with this consultation, not only those which are subject directly to CRDIV (i.e. in the UK, firms designated as CRR firms by the PRA and as IFPRU firms by the FCA) but also those subject to authorization under AIFMD or UCITS and those firms now classified as BIPRU firms, particularly where they are subsidiaries within groups which contain firms subject directly to CRDIV.
In summary, the key items that firms should look at include:
We strongly advise firms to engage fully with this consultation. This can be done directly or via trade bodies who will, without doubt, be submitting comprehensive submissions to this consultation.
It is vital that firms explain the difficulties with which they are presented, should the guidelines go ahead as drafted. What, for example, is the impact from the disapplication of proportionality with reference to its concepts and desired outcomes? Is it appropriate to apply the Cap to all, or even any staff, bearing in mind the desired outcomes this is intended to foster? Do firms have any concerns about the application on CRDIV groups containing subsidiaries not directly subject to CRDIV?
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