AFME has responded to FSA’s consultation on revisions to the Remuneration Code. Its main concerns are that there should be European and global consistency in dealing with remuneration incentives. It is worried that the further prescription that CRD3 introduces means it will be more difficult for firms to develop the most appropriate strategy and policy for their businesses. It also asks FSA to consult further on any changes it makes to the Code in light of the CEBS guidelines. The response highlights some aspects of FSA’s proposals that AFME feels may disadvantage firms where the changes do not directly flow from CRD3. The Association of Private Client Investment Managers and Stockbrokers (APCIMS) has also responded. It acknowledges FSA has little flexibility in implementing CRD3 and says it is pleased FSA acknowledges the differences between the firms the Code must now cover. It urges FSA to look at the commercial reality of different service types rather than on legalistic distinctions. It looks at the types of firm that will have difficulty applying the Code, or on whom the burden seems disproportionate. It states the market would be distorted if FSA applies the Code Principles in their entirety to all its member firms., and thinks there is a risk FSA will create an “unlevel playing field” with some of the non-CRD3 driven text.