Response to consultation Paper on draft Guidelines on the data collection exercise regarding high earners

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Q2: Is the information to be submitted to the EBA sufficiently clear?

Yes, the last reports have provided interesting information and the new report will be even more specific.

Q4: Are the reporting period and the specific amounts to be reported sufficiently clear?

Yes, but for the ease of reporting and in order to avoid double entries, it would be better to merge annex 1 of the report regarding high earners (EBA/CP/2014/05) with annex 2 of EBA/CP/2014/04 (remuneration benchmarking exercise).

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?

We agree with the analysis for high earners.

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UNI Europa