2011-10-12-奥纬咨询-IIF_Compensation_Reform_in_Wholesale_Banking_2011_40页_256kb

报告摘要

Compensation Reform in Wholesale Banking 2011: Assessing Three Years of Progress

This report analyzes the progress of wholesale banking compensation reforms following the FSB's Principles for Sound Compensation Practices. Conducted by the Institute of International Finance (IIF) and Oliver Wyman, it benchmarks how banks align their compensation structures with regulatory standards.

Context and Progress Overview

Key Areas of Progress:
- Risk-Aligned Compensation: Widespread adoption of deferral provisions, clawback mechanisms, and long vesting periods (average delay of 3 years).
- Payout Structures: Increased use of risk-adjusted metrics (e.g., profit after risk charges), multi-year deferrals, and equity-based incentives.
- Governance: Strengthened risk function independence and closer collaboration between remuneration committees and risk stakeholders.
Challenges Identified:
- Refinement of risk-adjusted data granularity (down to product or desk level).
- Development of stress testing for compensation schemes.
- Regulatory inconsistencies across jurisdictions and markets.

Key Areas for Ongoing Work

Risk Data: Enhancing metrics granularity, capital allocation transparency, and personal risk metric attribution.
Multi-Year Performance Data: Linking compensation payouts to longer-term business cycles.
Stress Testing: Incorporating scenario analysis into compensation design.
Material Risk Takers (MRTs): Defining and managing high-risk roles consistently across jurisdictions.

Disclosure and Future Outlook

Progress in Disclosure: Firms increasingly comply with FSB standards, but public disclosure remains culturally and legally variable.
Industry Challenges: Competition for talent may lead to single-year bonus guarantees, but reforms aim to stabilize incentives.
Regulatory Considerations: Balancing prescriptive standards with proportional implementation, addressing first-mover disadvantages in adopting reforms.

Conclusion

Banks have made consistent strides in aligning compensation with risk, but challenges in regulatory harmonization and granularity remain. Ongoing efforts are needed to ensure reforms contribute to financial stability and effective risk management.

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