FIA EPTA appreciates the opportunity to provide feedback to the European Banking Authority (EBA) Consultation on its Guidelines on remuneration policies for investment firms. FIA EPTA members note that the Draft EBA Guidelines on sound remuneration policies are very similar to the Guidelines EBA/GL/2015/22 dated 21 December 2015 currently in effect and applicable to firms subject to CRD V and MiFID firms, with minimal changes. Specifically, FIA EPTA members wish to point out that under the Guidelines EBA/GL/2015/22, some requirements are dependent on whether the firm is significant or not. In particular, a remuneration committee is not required for non-significant firms while a five-year deferral period is required for the management body of a significant firm. FIA EPTA members, therefore, conclude that the concept of significant firms used in CRD and related Guidelines that include mostly systematically important or similar credit institutions has been translated into Directive (EU) 2019/2034 (“IFD”) as firms with a balance sheet above EUR 100 million. The definition of significant has been materially changed but provisions to a large extent are applied equally. For this reason, FIA EPTA members believe that the provisions required under CRD and related Guidelines (particularly provisions dependent on being significant) should not be automatically carried forward under IFD.
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