The subject matter and scope are sufficiently clear.
The information to be submitted is sufficiently clear.
Numbers in example given in point 2.9 is incorrect, and insufficient in determining the level of detail required when reporting of the values. We propose that all numerical examples throughout the document are corrected and explicitly expressed.
The template itself is sufficiently clear. However, we strongly propose introduction of a glossary providing clear and understandable definitions and compilations for each reporting measure and category to ensure that the data gathered from each institution/group is comparable. We strongly encourage that, before introduction of the revised template, each term and metric used in the templates is clearly defined to promote validity and comparability of the data collected.
We note that references to terminology in the annex’s footnotes are somewhat faulty, and find them insufficient and burdensome to understand, as they only provide references to legislation, if any. For example term “independent control functions” is not defined anywhere in the document.
Annual collection of data is of sufficient frequency.
The deadline of 30 June each year is too early, and interferes with other processes related to remuneration. The deadline is proposed to be postponed to 31 October each year, or later.
Clarification and clear examples on whether or not the data should be reported on the paid-basis (i.e. remuneration actually paid during the year of reporting) or on the earnings-basis (i.e. remuneration earned during the year of reporting) should be provided to ensure unified interpretation of the data requested.
We would like to highlight that reporting for multi-year accrual periods distorts the data for organizations, who do not have rolling multi-year remuneration programs, and thus end up reporting somewhat disproportionate levels of remuneration awarded every three-five years, depending on the length of the earnings period of long-term incentive plans. For example, should an organization run only one long-term incentive program at a time, with earnings period of three years (i.e. 2008-2010, 2011-2013, etc.), earnings-based reporting would lead to high levels of reported remuneration for years 2010 and 2013, and significantly lower reported earnings for years 2008, 2009, 2011, and 2012. We note that this method of collecting the data may affect its quality, and strongly suggest considering the option of reporting remuneration on paid-basis.
We note that the rows in the Annex 1 somewhat differ to those of Annex 2 of the remuneration benchmarking exercise. We propose that these templates are kept identical to ease the collection of the data. For example, row considering “Article 450 h(iii)CRR – total amount of outstanding deferred variable remuneration awarded in previous periods and not in year N (in EUR)” is not included in the high earners Annex 1 template, but is found in Annex 2 of the total remuneration benchmarking data collection.
The time periods are insufficient considering that the revised guidelines shall apply from 1 July 2014, leaving only two months of July and August for the gathering of the data. The indicated two months are insufficient and challenging as they occur during the summer vacation season as well as overlap with budgeting processes. The deadline is proposed to be postponed to 31 October 2014, or later.
We also note that, should the deadline for the submission of data be postponed to 31 October 2014, the final guidelines should be available from 1 June 2014 the latest, in order to have sufficient time to react and apply the guidelines to data collection. Should the deadline for submission not be postponed, and the final guidelines be published later than 1 June 2014, meeting the proposed deadline will not be possible.
We somewhat agree with the analysis, however, we note that the increased granularity of the data collected does significantly increase costs of the data collection, as it is likely to cause need for manual processing. Possible changes to information systems may also cause additional costs.
We also note that the data collection process does not have any value adding features to the institutions themselves, and thus only serves the purposes of the authorities. We propose to develop the processes in closer cooperation with the institutions in the future to better incorporate the data collection exercises with the institutions' remuneration planning, and thus becoming a value adding exercises.