As mentioned in Regulatory Roundup 29, the consultation period in respect of the FSA’s proposed guidance on the Remuneration Code ended on 18 May.
As promised, and based upon feedback received, Complyport responded to the remuneration consultation with two issues.
The first concern was on the disclosure obligations in small firms – or any firm with few Code staff. In a 20 Code staff firm the aggregate disclosure obligation provides a reasonable guarantee of anonymity to those staff. The same would not necessarily be true in, say, a four person firm. Although the proposed guidance and FAQs raised the issue, it was felt that the response did not adequately address the concerns on confidentiality.
The second issue was on ‘risk takers’ and whether the concept has any meaning for a firm in proportionality tier 4.
