Response to consultation Paper on draft Guidelines on the remuneration benchmarking exercise
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Q3: Is the scope of consolidation for the data to be reported sufficiently clear?
The treatment of groups, comprising firms in and out of the scope of CRD (IV), in terms of supervision, remuneration and reporting is not clear and requires resolution, at least in the United Kingdom.Q5: Is the template in Annex 1 appropriate and sufficiently clear?
Yes.Q6: Is the template in Annex 2 appropriate and sufficiently clear?
Yes.Q7: Is the template in Annex 3 appropriate and sufficiently clear?
Yes.Q8: Are the reporting period, the specific amounts to be reported and the currency conversion sufficiently clear?
Yes.Q9: Are the indicated time periods sufficient to ensure that the data for 2013 can be collected in line with the updated Guidelines?
We believe that as CRD IV/R came into force in 2014, the 2014 performance year would be more appropriate for the data collection. As stated above, the treatment of groups has yet to be resolved and systems development takes time.Q10: 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?
As the treatment of groups has yet to be resolved and systems development takes time, firms may have go through the exercise to comply and then find out that they are no longer in scope.Upload files
IMA reply to EBA CP 2014-04.doc
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