Response to consultation Paper on draft Guidelines on the data collection exercise regarding high earners

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Q2: Is the information to be submitted to the EBA sufficiently clear?

Yes.

Q4: Are the reporting period and the specific amounts to be reported sufficiently clear?

Yes.

Q6: Do you agree with our analysis of the impact of the proposals in this Consultation Paper? If not, can you provide any evidence or data that would explain why you disagree or might further inform our analysis of the likely impacts of the proposals?

As the treatment of groups has yet to be resolved and systems development takes time, firms may have go through the exercise to comply and then find out that they are no longer in scope.

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Name of organisation

Investment Management Association