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Response to consultation on draft guidelines on the applicable notional discount rate for variable remuneration
Go backIs the example 2 sufficiently clear and helpful to understand the application of the guidelines?
Yes.Is the example 3 sufficiently clear and helpful to understand the application of the guidelines?
Yes.Do you agree with our analysis of the impact of the proposals in this CP? 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?
As above, we do not know if there is a demand for such instruments, especially from non-bank issuers (but caught in the scope of CRD), but think that as 40% of the investors, i.e. the employees of the issuers, can sell their stock of bonds, in whole or in part, after their deferral and retention periods have expired, demand and pricing may face downward pressure. In addition, such issuance will have to be considered by boards and investors, which takes time and costs money. As such, we do not believe that it is appropriate to require firms which are not of systemic importance and/or intermediate credit to issue them.Name of organisation
Investment Management Association
