The Investment Management Association, which represents the asset management industry operating in the UK has responded to Guidelines on Remuneration Policies and Practices (MiFID). The IMA has expressed three more general concerns relating to:
Scope - The draft guidelines which go beyond regulatory requirements in other international markets, are applicable globally to all EEA head quartered organisations. This means that non-EEA organisations will enjoy a competitive advantage in jurisdictions where they are not bound by such prescription of rules. The IMA welcomes ESMA’s recognition through proportionality clauses of the huge variety of size in business models and firms that will be covered by the guidelines. It supports a flexible approach, it allows firms to balance a variety of risk adjustment techniques to achieve a remuneration model that best matches their business requirements and risk framework.
Alignment - It is likely that several sets of remuneration regulations, home and host, EU and third Country, will apply. The IMA would welcome further guidance on ESMA and how this would work in practice.
The European Fund and Asset Management Association (EFAMA), the Alternative Investment Management Association (AIMA), the European Savings Bank Group (ESBG), European Banking Federation (EBF) and Managed Funds Association (MFA) have also responded to the Remuneration Policies and Practices.