MFA submitted a comment letter to the FCA PRA regarding their joint Consultation on remuneration reform.
The FCA/PRA are seeking to simplify the regime for dually-regulated (by both PRA and FCA) firms.
MFA’s comment letter supports the objectives of simplifying and harmonizing the remuneration requirements, but notes:
- Corresponding changes will have to be made to the remuneration rules for firms that are not dually PRA/FCA regulated or the goals of the Consultation will be undermined and
- Support of proposals to
- Exempt small dually-regulated from rules on buy-outs
- Amend the remuneration threshold when dually-regulated firms may disapply certain remuneration rules for designated risk-taking employees
- Introduce guidance to reflect that dually-regulated firms are not expected to set a retention period for deferred instruments and
- Remove the ban on the payment of dividends or interest on deferred remuneration.