AIMA responds on remuneration: AIMA's response to EBA's consultation paper on guidelines on sound remuneration practices under the fourth Capital Requirements Directive (CRD4) notes several significant concerns. AIMA is worried about:

  • EBA's interpretation of the proportionality principle. It says EBA's interpretation could have serious negative implications for AIMA members and that it should (as CRD4 requires) allow firms to neutralise certain provisions of the remuneration principles where proportionate to do so;
  • EBA's proposal to apply the guidelines to staff of delegate entities of a CRD4 group company. It says CRD4 does not mention any requirements applying to staff outside the group; and
  • possible tax consequences of the proposed guidelines on limited liability partnerships or limited partnerships if dividends paid to a CRD4 group company's shareholders or profit allocations to partners or members of partnerships are considered remuneration where those individuals are otherwise "identified staff" as well. AIMA does not think these payments are remuneration but sees disproportionate tax consequences if they are treated as such.

(Source: AIMA Responds on Remuneration)