EBA · 2023_6808 Rejected question

Remuneration policy disclosure regarding Management Bodies of subsidiaries of an EU parent institution

Regulation
Regulation (EU) No 575/2013 (CRR)
Article
450
Topic
Transparency and Pillar 3
Submitted by
Consultancy firm
Submitted
2023-05-22
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Question

We would appreciate the EBA to shed light on the disclosure requirements about remuneration for EU parent institutions for the purpose of the Pillar 3 Disclosure Report and under Annex XXXIV of the Commission Implementing Regulation (EU) 2021/637. Indeed, requirements under the Annex stipulate that information on members of the Management Body disclosed under “Template EU REM1 – Remuneration awarded for the financial year” shall, in accordance with Article 13 CRR, be disclosed on the basis of their consolidated situation. In such case, the disclosure entity will solely reflect, in the columns related to Management Body, information on their own management body while information on the identified staff of the management bodies of subsidiaries shall be disclosed under the relevant business area. We would kindly ask for detailed explanations on how EU parent institutions shall disclose the Management Body members of their subsidiaries in terms of columns within “Template EU REM1 – Remuneration awarded for the financial year” (i.e., under column a/b, c or d) and “Template EU REM5 – Information of staff whose professional activities have a material impact on institutions’ risk profile (identified staff)”.

Background

A common understanding of this disclosure requirement seems not to be shared by all EU parent institutions as we noticed discrepancies in the application of these requirements in practice. For instance, certain EU parents institutions seem only to report information about their own Management Body in columns a & b of “Template EU REM1 – Remuneration awarded for the financial year” but report information on Management Body members of subsidiaries either under columns c or d, whereas others report information on all Management Body members, including members of subsidiaries in columns a & b.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2023_6808

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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