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Response to consultation on Guidelines on sound remuneration policies
Go backQ 4: Are the guidelines regarding remuneration policies and group context appropriate and sufficiently clear?
Some parts are unclear regarding the consistency between Chapter 4 and Chapter 5. Can you please clarify why on page 11 says The scope of consolidation includes all institutions and financial institutions that are subsidiaries of the institution which is responsible for the consolidation; where requirements refer to the ‘consolidated basis’ or 'consolidated situation’ the responsible EU parent institution, EU parent financial holding company or EU parent mixed financial holding company is responsible for the compliance with the respective CRD provisions and guidelines" and it in Point 50 of page 105 says that "As the consolidating institution is responsible for the compliance on the group level...". In definitions on page 23 it says that the consolidating institution is the institution which is responsible for the prudential consolidation or sub-consolidation under Article 18 of CRR. A parent financial holding company is not an institution and could thus not classify as a consolidating institution. In the case of a group structure with a parent financial holding company, the consolidating institution is a subsidiary of the parent financial holding company. Is the text on page 11 incorrect regarding that a financial holding company can be responsible for the compliance with the respective CRD provisions and guidelines? Also, shouldn't it say "The scope of consolidation includes all institutions and financial institutions that are subsidiaries of the institution which is responsible for the consolidation or, where relevant, the subsidiaries of the same parent financial holding company or parent mixed financial holding company."?"
