2014年-EBA欧洲银行管理局_EBA_Remuneration_benchmarking_report_2010_to_2012_30页_1mb

EBA Report Summary: Benchmarking of Remuneration Practices at Union Level

Core Content

The European Banking Authority (EBA) conducted a benchmarking exercise on remuneration practices across Union and EEA institutions, based on data from 2010 to 2012, in line with Directive 2013/36/EU (CRD IV) and Regulation (EU) No 575/2013. The objective was to evaluate remuneration trends and ensure compliance with regulatory requirements, particularly regarding variable remuneration (bonuses) and the identification of staff with a material impact on the risk profile of institutions.

Main Viewpoints

• Legal Basis:
  The remuneration requirements were initially introduced under CRD III (Directive 2010/76/EU) and further developed under CRD IV (Directive 2013/36/EU). These regulations require the identification of staff (referred to as "identified staff") and impose restrictions on variable remuneration, including a cap of 100% (200% with shareholder approval) for the variable-to-fixed remuneration ratio for identified staff starting from 2014.

• Data Collection:

  • Data was collected for 2010 to 2012, with 137 groups submitting data for 2012, 124 for 2011, and 113 for 2010.
  • The data was collected at the EEA consolidation level, covering all subsidiaries and branches of EEA institutions.
  • The EBA issued Guidelines on remuneration benchmarking and Guidelines on high earners to standardize the data collection process.

• Remuneration Trends:

  • Fixed remuneration increased over time, while variable remuneration decreased, particularly in 2012.
  • The average variable/fixed remuneration ratio dropped from 204.76% in 2010 to 108.74% in 2012, reflecting the impact of regulatory changes and reduced profitability.
  • The percentage of high earners (staff earning more than EUR 1,000,000 annually) slightly increased from 0.97% in 2010 to 1.20% in 2012.
  • In the UK, the percentage of high earners was notably higher than in other Member States.

• Identified Staff:

  • Identified staff are those whose professional activities have a material impact on the risk profile of an institution.
  • The percentage of high earners who are identified staff increased from 41.44% in 2010 to 53.68% in 2012.
  • The RTS on identified staff requires that at least 0.3% of the staff with the highest remuneration be identified, leading to an increase in the identified staff ratio in some institutions.

• Deferral of Variable Remuneration:

  • A minimum deferral of 40% of variable remuneration was introduced in 2011, increasing to 60% for particularly high amounts.
  • The average deferral percentage for identified staff in 2012 was below 40% in some cases, indicating that many institutions did not fully comply with the deferral requirements.
  • The EBA noted a tendency for institutions to only meet the minimum deferral requirements, rather than applying higher deferrals to better align with risk.

• Specific Remuneration Elements:

  • The EBA analyzed ex-post risk adjustments, guaranteed variable remuneration, severance payments, and discretionary pension benefits.
  • These elements are often used by institutions to manage risk and align remuneration with performance, but they were not uniformly applied across the Union.
  • Guaranteed variable remuneration was awarded to a significant number of staff, with the total amount increasing over time.
  • Severance payments and discretionary pension benefits were also analyzed, with median values reported for each.

Key Information

• High Earners:

  • Defined as staff earning more than EUR 1,000,000 annually.
  • In 2012, the total number of high earners across all Member States was 3,530, with 1,895 being identified staff.
  • The EBA published aggregated data on high earners, showing that 53.68% of high earners were identified staff in 2012.

• Remuneration Components:

  • Fixed remuneration increased in 2012, contributing to a lower variable/fixed ratio.
  • Variable remuneration (including bonuses and long-term incentives) was reduced, likely due to regulatory changes and economic conditions.
  • Deferred variable remuneration increased in most cases, but still fell below the 40% minimum requirement in some institutions.

• Business Lines:

  • The percentage of identified staff varied across different business lines.
  • Investment banking had the highest percentage of identified staff.
  • Asset management and retail banking had lower but still significant percentages.
  • The "all other" category included corporate functions such as management, IT, HR, and control.

• Regulatory Implications:

  • The EBA is working with the European Commission and co-legislators to ensure compliance with the RTS on identified staff.
  • There is concern over the use of allowances as a means to circumvent remuneration caps.
  • The EBA will continue to publish annual benchmarking reports to monitor compliance and provide transparency.

Conclusion

The EBA's analysis shows that remuneration practices across the Union are not yet fully harmonized, despite regulatory efforts. The focus on deferral, risk alignment, and identification of key staff remains a priority. As CRD IV is implemented, the cap on variable remuneration and the stricter identification criteria are expected to further influence remuneration structures and practices.