Response to consultation Paper on draft Guidelines on the remuneration benchmarking exercise
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In addition, we strongly propose introducing a glossary providing clear and understandable definitions for each reporting category. The references to terminology in the footnotes are insufficient and difficult to understand, sometimes even inconsistent. For example:
- There is no definition of independent control functions, Headcount and Full Time Equivalent (FTE)
- Definition of the members of the management body in its supervisory function in Annex 1 is different than in Annex 2, and is not sufficiently clear for an institution to be able to apply it.
- Definition of the members of the management body in its management function in Annex 1 is different than in Annex 2, and is not sufficiently clear for an institution to be able to apply it.
The term awarded is not sufficiently clear, and we strongly propose that concrete numerical examples are given to ensure common interpretation of the term award"."
The reporting period and the currency conversion are sufficiently clear.
However, the example given in point 6.5. is not clear, and we would call for clarifying what is meant by “full amounts in euro”.
We would strongly call for extending the deadline to at least 31 October 2014, subject to availability of the final GL by 1 June 2014 the latest. Any later publication would need to be linked with a further postponement of the deadline for submission of the information.
We also note that the data collection process does not have any value added features for the institutions themselves. We propose to develop the processes in closer cooperation with the institutions in the future to better incorporate the data collection exercises with the institutions' remuneration planning, and thus becoming a mutually beneficial exercises, for both supervisors and institutions.
Q3: Is the scope of consolidation for the data to be reported sufficiently clear?
The scope is sufficiently clear.Q5: Is the template in Annex 1 appropriate and sufficiently clear?
In general, the template is very detailed. Provision of such detailed level of information will require significant resource and time investments on the part of credit institutions. This will result in excessive costs, especially for smaller institutions.In addition, we strongly propose introducing a glossary providing clear and understandable definitions for each reporting category. The references to terminology in the footnotes are insufficient and difficult to understand, sometimes even inconsistent. For example:
- There is no definition of independent control functions, Headcount and Full Time Equivalent (FTE)
- Definition of the members of the management body in its supervisory function in Annex 1 is different than in Annex 2, and is not sufficiently clear for an institution to be able to apply it.
- Definition of the members of the management body in its management function in Annex 1 is different than in Annex 2, and is not sufficiently clear for an institution to be able to apply it.
Q6: Is the template in Annex 2 appropriate and sufficiently clear?
In addition to our comments under question 5, we would like to call for a clarification, with clear examples, of whether the data should be reported on the paid-basis (i.e. remuneration actually paid during the year of reporting) or on the earnings-basis (i.e. remuneration earned during the year of reporting, but not fully paid to the individual).The term awarded is not sufficiently clear, and we strongly propose that concrete numerical examples are given to ensure common interpretation of the term award"."
Q7: Is the template in Annex 3 appropriate and sufficiently clear?
The template is appropriate and sufficiently clear, however too detailed for smaller institutions (see our comment on proportionality under question 5).Q8: Are the reporting period, the specific amounts to be reported and the currency conversion sufficiently clear?
We would call for a clarification with clear examples of whether the data should be reported on the pay-out-basis (i.e. remuneration actually paid during the year of reporting) or on the earnings-basis (i.e. remuneration earned during the year of reporting, but not fully paid to the individual). The term awarded is not sufficiently clear, and we strongly propose that concrete numerical examples are given to ensure common interpretation of the term award.The reporting period and the currency conversion are sufficiently clear.
However, the example given in point 6.5. is not clear, and we would call for clarifying what is meant by “full amounts in euro”.
Q9: Are the indicated time periods sufficient to ensure that the data for 2013 can be collected in line with the updated Guidelines?
The time periods are insufficient considering that the revised guidelines shall apply from 1 July 2014, leaving only two months (July and August) for the gathering of the data. The indicated two months are insufficient and challenging as they occur during the summer vacation season as well as overlap with budgeting processes. This will not allow to submit the data on time.We would strongly call for extending the deadline to at least 31 October 2014, subject to availability of the final GL by 1 June 2014 the latest. Any later publication would need to be linked with a further postponement of the deadline for submission of the information.
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?
We can to a certain degree agree with the analysis. However, we would like to underline that the increased granularity of the data collected significantly increases costs of the data collection process for each institution.We also note that the data collection process does not have any value added features for the institutions themselves. We propose to develop the processes in closer cooperation with the institutions in the future to better incorporate the data collection exercises with the institutions' remuneration planning, and thus becoming a mutually beneficial exercises, for both supervisors and institutions.