2016年-EBA欧洲银行管理局_EBA_Op-2016-05__28Report_on_Benchmarking_of_Remuneration_and_High_Earners_201429_88页_2mb

EBA Report Summary: Benchmarking of Remuneration Practices at the EU Level and Data on High Earners (Data as of End 2014)

Core Content

The European Banking Authority (EBA) published this report as part of its obligations under Directive 2013/36/EU (CRD IV) to benchmark remuneration practices at the EU level and to publish aggregated data on high earners earning EUR 1 million or more annually. The report includes data for the year 2014, which was collected from 143 groups and institutions, with a focus on identifying trends and assessing the impact of regulatory changes on remuneration structures and institutional cost flexibility.

Main Figures from the Remuneration Benchmarking Exercise

Key Findings

1. High Earners and Identified Staff

• Increase in High Earners: The number of high earners (those earning EUR 1 million or more) increased by 21.6%, from 3,178 in 2013 to 3,865 in 2014. This increase was largely due to the EUR-GBP exchange rate fluctuation, which inflated GBP salaries when converted to EUR.
• UK Dominance: The UK accounted for the largest number of high earners in 2014, with 2,926 high earners, up by 40.27% from 2013. Most of these high earners were paid in GBP.
• Overlap with Identified Staff: The proportion of high earners who are identified staff increased from 59% in 2013 to 87% in 2014, indicating a stronger alignment between high earners and those with a material impact on risk profiles. This increase was due to the implementation of the RTS on identified staff in June 2014.

2. Remuneration Trends and Regulatory Impact

• Bonus Cap Effect: The introduction of the bonus cap (limiting the variable-to-fixed remuneration ratio to 100%, with 200% allowed with shareholder approval) significantly reduced the average variable-to-fixed remuneration ratio for identified staff from 104.27% in 2013 to 65.48% in 2014.
• Variable Remuneration and Shareholder Payments: In many institutions, variable remuneration for all staff roughly equals half of the amount paid out to shareholders, indicating a potential link between executive pay and shareholder returns.
• Fixed Remuneration: The increase in the number of identified staff led to a rise in fixed remuneration, but it remained below 5% of administrative costs in most institutions, suggesting minimal impact on cost flexibility.

3. Deferral and Payout of Variable Remuneration

• Deferral Trends: There was a small increase in the percentage of variable remuneration deferred and paid out in instruments in 2014. For the first time, a noticeable amount of fixed remuneration was also paid out in instruments, likely due to the inclusion of role-based allowances under fixed remuneration.
• Instrument Payouts: The ratio of deferred variable remuneration to total variable remuneration varied across Member States and payment brackets, with a general trend towards deferral in 2014.

4. Special Elements of Variable Remuneration

• Ex Post Risk Adjustments: These were applied to identified staff in various business areas, with the highest amounts in investment banking.
• Guaranteed Variable Remuneration: This was awarded to a significant number of identified staff, with the highest total amounts in investment banking and the highest median amounts in retail banking.
• Severance Payments: The total amount of severance payments to high earners increased, with the highest amounts in investment banking and asset management.
• Discretionary Pension Benefits: These were granted to a smaller number of staff, with the highest median amounts in corporate functions.

Regulatory Context and EBA's Role

• The EBA issued updated Guidelines in July 2014 to ensure data reflects changes in remuneration requirements under CRD IV and disclosure under CRR.
• The bonus cap significantly influenced remuneration structures, reducing variable-to-fixed ratios and promoting more sustainable compensation practices.
• The EBA continues to monitor and evaluate remuneration practices, contributing to the European Commission’s review under Article 161(2) of CRD IV.
• The EBA also published an Opinion on proportionality in December 2015, suggesting that small and non-complex institutions may be allowed to waive deferral requirements and payout in non-cash instruments for certain staff.

Data Collection and Reporting

• Data was collected at the highest level of consolidation (EU level), covering all subsidiaries and branches in other Member States and third countries.
• 60% of the banking system (by total assets) in each Member State is required to be included in the data.
• High earners data was collected separately and published at the EU level, with details by Member State and remuneration bracket.
• Exclusions from the identified staff category were allowed in exceptional cases, but were rare and required justification.
• The definition of high earners differs slightly from that of identified staff, which can result in some high earners not being classified as identified staff.

Conclusion

The report highlights a significant shift in remuneration practices following the implementation of the RTS on identified staff and the bonus cap. The number of high earners increased due to exchange rate changes, and the overlap between high earners and identified staff improved, reflecting better alignment with risk management principles. The EBA continues to play a central role in benchmarking and monitoring these trends, ensuring consistency and transparency in remuneration practices across the EU.