Response to consultation on draft RTS on the minimum content of the governance arrangements on the remuneration policy under MiCAR

Go back

Question 1. Are the definitions within Article 1 appropriate and sufficiently clear?

We believe that the main definitions included in Article 1 are sufficiently clear and appropriate.

Question 2. Are the provisions within Article 2 appropriate and sufficiently clear?

We believe that the RTS are sufficiently clear and appropriate, and promote level-playing field in the ARTs sector.

Question 3. Are the provisions within Article 3 appropriate and sufficiently clear?

The RTS are sufficiently clear and appropriate and promote level-playing field in the ARTs sector.
However, we suggest that the reference to fixed and variable remuneration be replaced with fixed/recurring remuneration and variable/non-recurring remuneration in order to avoid misinterpretations and align the RTS with the rules of remuneration policies for investment firms

Question 4. Are the criteria of identification of staff appropriate and sufficiently clear?

We basically agree on every aspect of Article 4.

Question 5. Are the provisions within Article 5 appropriate and sufficiently clear?

We suggest to include in point (g) the provision of a ratio of 1:1 between the variable component and the fixed component of the remuneration of the most relevant personnel and that this limit can be raised to a ratio not exceeding 200% (a ratio of 2:1) only temporarily and following motivated evaluations, as provided for by the CRD3 Directive.

Question 6. Is the possibility of paying a part of variable remuneration in significant asset-referenced tokens issued by the issuer appropriate also considering the still limited market experience on these instruments?”

We think that paying a part of variable remuneration in significant ARTs issued by the issuer is just as appropriate as paying part of the variable remuneration with corporate shares issued by the issuer.

Name of the organization

ANASF