2010年-FSB全球金融稳定委员会_Thematic_Review_on_Compensation_2010_39页_563kb

Thematic Review on Compensation Summary

Core Content

The Financial Stability Board (FSB) conducted a peer review of the implementation of the Financial Stability Forum's (FSF) Principles for Sound Compensation Practices and their Implementation Standards, following the G20 Leaders' directive from the Pittsburgh Summit in September 2009. This review aimed to assess the progress made by FSB member jurisdictions and significant financial institutions in aligning compensation policies with prudent risk-taking and to make recommendations for further improvements.

Main Findings

• Regulatory and Supervisory Progress: Over the past year, significant changes have occurred in regulatory and supervisory frameworks across FSB members. Many jurisdictions have adopted a mix of enforceable regulations and supervisory oversight. Some have issued separate regulations, while others have integrated the Principles into existing frameworks.

• Implementation Pace and Approach: There are differences in the pace and approach of implementation across jurisdictions. While some countries have made substantial progress, others are still in the preparatory or early implementation stages. The review emphasizes the need for sustained and cooperative efforts to fully implement the Principles and Standards by the end of 2010.

• Governance of Compensation: New rules have been introduced in many jurisdictions that extend existing corporate governance requirements. Most require boards to oversee compensation systems, with some mandating the establishment of dedicated sub-committees. The composition of remuneration committees varies, with some requiring a majority of non-executive directors and others having less specific requirements.

• Risk Adjustment of Pay: There is a general recognition of the need to align compensation with risk, though the quality and detail of these adjustments vary. Jurisdictions are working to ensure that financial institutions have appropriate methods to account for risks, including future risks not captured by accounting profits.

• Variable Pay and Capital Conservation: Several jurisdictions have introduced measures to limit variable compensation in line with capital conservation principles. Others are planning to do so through legislation or regulation. The FSB recommends further work to standardize these practices.

• Symmetry with Risk Outcomes: Most jurisdictions require compensation outcomes to be symmetric with risk outcomes, ensuring that poor financial performance leads to a reduction in variable pay. However, the proportion of variable pay in total compensation is not universally specified, and there are differing views on what constitutes a "substantial" share.

• Payout Structures and Schedules: Jurisdictions have incorporated deferral and malus mechanisms into their frameworks. Some have specific minimum expectations for deferred amounts and periods, while others use more general terms. The review highlights the importance of aligning these structures with risk profiles and long-term interests.

• Disclosure Requirements: There has been progress in promoting transparency through disclosure requirements. The FSB recommends incorporating these into Pillar 3 of Basel II for greater specificity.

Key Recommendations

1. Finalise and Implement Regulatory Initiatives: FSB members should finalise and implement regulatory or supervisory initiatives related to the Principles and Standards in 2010.

2. Continue Risk Alignment Progress: Firms should continue to align their compensation schemes with risk and performance, demonstrating how they incorporate risk adjustments.

3. Enhance Supervisory Cooperation: International supervisory colleges should enhance information exchange and cooperation on compensation issues, especially for cross-border firms.

4. Bilateral Coordination: Jurisdictions hosting significant institutions from another country should coordinate to ensure consistency across firms.

5. Apply Standards to All Significant Institutions: All significant financial institutions in the financial services sector should follow sound compensation practices, regardless of legal form.

6. Ensure Compensation Committee Standards: Supervisors should ensure that compensation committees are composed of appropriately qualified and independent members.

7. Develop Risk Adjustment Methodologies: The Basel Committee should develop a report on methodologies for risk and performance alignment of compensation schemes by the end of October 2010.

8. Incorporate Disclosure into Basel II: The Basel Committee, in consultation with the FSB, should consider incorporating compensation disclosure requirements into Pillar 3 of Basel II by the end of 2010.

9. Conduct Follow-up Review: The FSB should conduct a follow-up review in the second quarter of 2011 to assess the impact of implemented measures and industry compliance.

10. Develop Implementation Criteria: The FSB should develop criteria for assessing progress in implementing the Principles and Standards.

Scope of Application

• Institutional Coverage: Most jurisdictions apply the Principles and Standards to a subset of significant institutions, often based on size thresholds. A few apply them to all institutions, subject to proportionality.

• Nonbank Financial Institutions: Insurance companies and asset management firms are generally covered if they are part of a banking group. Some jurisdictions are planning to extend coverage to all nonbank financial institutions.

• Employee Categories: Compensation policies generally cover senior management, material risk-takers, and staff in risk management and control functions. Some jurisdictions cover all employees with variable compensation, while others apply proportionality principles.

Supervisory Activities

• Self-Assessment and Compliance Reviews: Jurisdictions have conducted self-assessments and compliance reviews of significant financial institutions, including on-site visits and interviews with senior management.

• Ongoing Supervision: Enhanced supervision of compensation practices is expected to continue in 2010, with monitoring becoming part of ongoing on- and off-site supervision.

• Training Programs: The Netherlands and Switzerland have launched internal training programs for examining officers to improve understanding and enforcement of compensation rules.

Conclusion

The peer review highlights the progress made in aligning compensation practices with prudent risk-taking and the need for continued efforts to ensure effective and sustained implementation. It recommends further measures to improve risk adjustment, enhance supervisory cooperation, and expand coverage to all significant financial institutions. The FSB plans to conduct a follow-up review in 2011 to assess the ongoing impact and compliance with the Principles and Standards.