The European Association of Co-operative Banks welcomes the opportunity to participate in the public consultation of the EBA draft Guidelines on sound remuneration. Generally, we support the EBA initiative to update the 2010 CEBS Guidelines in order to enable consistent, efficient and effective implementation of the requirements by the institutions and promote sound compensation practices for the entire financial sector. At the same time, however, we note that the new EBA draft Guidelines significantly change remuneration and compensation rules applicable EU-wide. On a number of issues the EBA draft Guidelines overstep the CRD IV requirements and effectively amend them requiring wider and stricter application.
EACB members are very concerned about the EBA approach on proportionality, according to which smaller and non-complex institutions would be required to comply with remuneration provisions in a similar to systemically important institutions way. In addition, the new draft Guidelines seem to target a larger scope of staff members and not only the material risk takers, as envisaged under the CRD IV. The EBA draft rules might not be always in line with the national legal provisions, which have been recently amended to correspond to the CRD IV. In our view this may create unsound legal environment and lead to unnecessary administrative and practical burdens for regulators, supervisors and institutions.
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