BBA has published its response to FSA's draft Code on Remuneration Policies, which it submitted to FSA in May. It supports the risk-based approach and the idea of linking remuneration policy to risk management. However, it is concerned:  

  • FSA is "front-running" the rest of the world in forcing change, and this is bad as there should be a level playing field both between institutions and between countries;  
  • BBA would prefer the Code to set out principles rather than the current prescriptive approach; and  
  • it may not always be appropriate to place performance measures on the deferred element of any bonus.