Response by the FIA European Principal Traders Association to the EBA Consultation Paper on draft RTS on revised identified staff for remuneration purposes

18 February 2020

Principal Trading Firms are relatively small, non-complex firms with flat organization structures. Importantly, our members trade for own account and risk only, and do not hold or manage client assets or money or take deposits. Therefore, the conflict of interest risks for which the prudential remuneration rules are designed are not present in Principal Trading Firms. We would suggest,therefore, to EBA to consider any unintended consequences which may lead to disproportionate outcomes for smaller firms with flat organizational structures and very targeted activities, such as our members.