The CLLS has also responded to the FCA’s September consultation paper on its proposals to amend the rules and guidance on remuneration policies and practices under CRD IV. The key issue for the CLLS concerns the FCA's policy on retention awards. The CLLS notes that it understands the FCA and PRA do not intend to adopt significantly differing policy approaches to the remuneration code requirements in the context of the new EBA guidelines coming into force on 13 January 2018. However, it highlights the fact that the FCA’s policy on retention awards is different from that indicated by the PRA and the EBA guidelines, namely that retention awards are different from guaranteed variable remuneration. The CLLS suggests that the FCA clarifies this for the purposes of both the SYSC 19A and SYSC 19D remuneration codes.