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报告摘要

EBA Public Hearing on Guidelines on the Discount Rate for Variable Remuneration

Core Content

The European Banking Authority (EBA) conducted a public hearing on 29 November 2013 regarding the guidelines on the discount rate for variable remuneration. These guidelines are part of the Capital Requirements Regulation (CRR) and aim to ensure consistency in the application of discount rates across the European Union.

Legal Background and EBA’s Mandate

The EBA is mandated to issue guidelines on the applicable notional discount rate by 31 March 2014, as stipulated in:

Article 16 of the EBA Regulation, which requires the EBA to prepare and publish guidelines.
Second sub-paragraph of Article 94(1)(g)(iii) of Directive 2013/36/EU, which emphasizes the need to consider inflation rate and risk, including the length of deferral, when setting the discount rate.

These guidelines are intended to encourage the use of long-term deferred variable remuneration instruments, particularly those deferred for at least five years.

Elements of the Discount Rate

The guidelines define the discount rate based on several factors:

Inflation rate: The rate of the Member State or a comparable index for other currencies. A specific rule applies to staff in third countries.
Inflation risk: Based on the average rate of EU government bonds across the EU28.
Incentive factor for long-term deferral: 10% for a five-year deferral period, plus an additional 2% for each full additional year.
Incentive factor for retention periods: 2% for a two-year retention period, plus 1% for each additional full year.

Application of the Discount Rate

The discount rate is calculated using the following formula:

$$
\text{discount rate} = \frac{1}{(1 + i + g + id + ir)^{n}}
$$

Where:

$ i $ = inflation rate of the Member State or third country
$ g $ = interest rate for EU government bonds, EU average
$ id $ = incentive factor for use of long-term deferral
$ ir $ = incentive factor for retention
$ n $ = number of years of the vesting period

This formula is used to determine the discount applied to variable remuneration paid in deferred instruments, ensuring that the discount reflects the time value of money and the risk associated with deferral.

Public Consultation

The consultation paper (CP) was published on 23 October 2013.
The consultation period ended on 18 January 2014.
A public hearing was held on 29 November 2013.
Interested parties were invited to submit written comments via the EBA’s website: www.eba.europa.eu.

Key Information

Variable remuneration limits: For identified staff, variable remuneration is limited to 100% (200%) of the fixed remuneration.
Discount application: Up to 25% of variable remuneration can be discounted if paid in instruments deferred for at least five years. Member States may set lower percentages or choose not to allow any discount.
Deferral and payment structure:
- At least 40%–60% of variable remuneration is deferred.
- At least 50% of variable remuneration is paid in instruments.
- 25% of variable remuneration is paid in instruments deferred for at least five years, which is eligible for discount.

Summary of Main Points

The EBA is tasked with developing guidelines on the notional discount rate for variable remuneration, which must consider inflation, risk, and the length of deferral.
The guidelines aim to incentivize the use of long-term deferred variable remuneration instruments.
The discount rate is calculated using a formula that incorporates inflation, interest rates, and incentive factors for deferral and retention periods.
A public consultation period was opened to gather feedback, with a deadline of 18 January 2014.