Response to consultation Paper on draft Guidelines on the data collection exercise regarding high earners
Go back
Values are to be indicated in € and not in millions of €, as provided for in the 2012 guidelines.
As concerns the request in 3.4, it should be better specified what is meant by “do not revolve on an annual basis”; it is assumed that this has to do with systems where the new multi-year plan begins only when the previous plan ends.
Then for the other multi-year plans (“revolve on an annual basis”) the remunerations shall be recognised proportionally over the different fiscal years to which they pertain.
The additional information requested concern the disaggregation of the variable deferred remuneration in cash, stock and instruments linked to other financial instruments. There is no provision for the identification of the deferred remuneration paid in instruments for at least 5 years, to which it will be possible to apply the nominal discount rate, which is the reason indicated on page 18, which would justify the additional information included.
In addition, there have been included requests in terms of severance and variable remuneration assigned for multi-year periods, regarding which there is no evidence of EU legislation.
The affects connected to the legislation – not pointed out in the document - have their origins in the implementation of the new system, only in part attributable to the EU legislation (one off cost) and to the ongoing cost for reclassification in case the personnel change position and job.
Q2: Is the information to be submitted to the EBA sufficiently clear?
We agree with the provision to use the variable “number of heads” in the place of the FTE, referring to the staff in service at the end of the year.Values are to be indicated in € and not in millions of €, as provided for in the 2012 guidelines.
Q4: Are the reporting period and the specific amounts to be reported sufficiently clear?
The reporting period and the specific amounts to be reported are sufficiently clear.As concerns the request in 3.4, it should be better specified what is meant by “do not revolve on an annual basis”; it is assumed that this has to do with systems where the new multi-year plan begins only when the previous plan ends.
Then for the other multi-year plans (“revolve on an annual basis”) the remunerations shall be recognised proportionally over the different fiscal years to which they pertain.
Q6: Do you agree with our analysis of the impact of the proposals in this Consultation Paper? If not, can you provide any evidence or data that would explain why you disagree or might further inform our analysis of the likely impacts of the proposals?
The greater granularity of the requests, as in terms of the greater disaggregation of the business areas as of the information requested, does not represent a direct consequence of the provisions contained in the Regulation and in the EU Directive; therefore it should be assessed within the economic impact of the guidelines.The additional information requested concern the disaggregation of the variable deferred remuneration in cash, stock and instruments linked to other financial instruments. There is no provision for the identification of the deferred remuneration paid in instruments for at least 5 years, to which it will be possible to apply the nominal discount rate, which is the reason indicated on page 18, which would justify the additional information included.
In addition, there have been included requests in terms of severance and variable remuneration assigned for multi-year periods, regarding which there is no evidence of EU legislation.
The affects connected to the legislation – not pointed out in the document - have their origins in the implementation of the new system, only in part attributable to the EU legislation (one off cost) and to the ongoing cost for reclassification in case the personnel change position and job.
Upload files
high earners 07_05_2014_EBA.pdf
(51.44 KB)