Submission #76

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Deutscher Sparkassen- und Giroverband

Q 1: Are the definitions provided sufficiently clear; are additional definitions needed? See comments attached

Q 2: Are the guidelines in chapter 5 appropriate and sufficiently clear? See comments attached

Q 3: Are the guidelines regarding the shareholders’ involvement in setting higher ratios for variable remuneration sufficiently clear? See comments attached

Q 4: Are the guidelines regarding remuneration policies and group context appropriate and sufficiently clear? See comments attached

Q 5: All respondents are welcome to provide their comments on the chapter on proportionality, with particular reference to the change of the approach on ‘neutralisations’ that was required following the interpretation of the wording of the CRD. In particular institutions that used ‘neutralisations’ under the previous guidelines for the whole institution or identified staff receiving only a low amount of variable remuneration are asked to provide an estimate of the implementation costs in absolute and relative terms and to point to impediments resulting from their nature, including their legal form, if they were required to apply, for the variable remuneration of identified staff: a) deferral arrangements, b) the pay out in instruments and, c) malus (with respect to the deferred variable remuneration). In addition those institutions are welcome to explain the anticipated changes to the remuneration policy which will need to be made to comply with all requirements. Wherever possible the estimated impact and costs should be quantified, supported by a short explanation of the methodology applied for their estimation and provided separately for the three listed aspects. See comments attached

Q 6: Are the guidelines on the identification of staff appropriate and sufficiently clear? See comments attached

Q 7: Are the guidelines regarding the capital base appropriate and sufficiently clear? NA

Q 8: Are the requirements regarding categories of remuneration appropriate and sufficiently clear? NA

Q 9: Are the requirements regarding allowances appropriate and sufficiently clear? NA

Q 10: Are the requirements on the retention bonus appropriate a sufficiently clear? NA

Q 11: Are the provisions regarding severance payments appropriate and sufficiently clear? See comments attached

Q 12: Are the provisions on personal hedging and circumvention appropriate and sufficiently clear? NA

Q 13: Are the requirements on remuneration policies in section 15 appropriate and sufficiently clear? NA

Q 14: Are the requirements on the risk alignment process appropriate and sufficiently clear? NA

Q 15: Are the provisions on deferral appropriate and sufficiently clear? See comments attached

Q 16: Are the provisions on the award of variable remuneration in instruments appropriate and sufficiently clear? Listed institutions are asked to provide an estimate of the impact and costs that would be created due to the requirement that under Article 94(1)(l)(i) CRD only shares (and no share linked instruments) should be used in parallel, where possible, to instruments as set out in the RTS on instruments. Wherever possible the estimated impact and costs should be quantified and supported by a short explanation of the methodology applied for their estimation. See comments attached

Q 17: Are the requirements regarding the retention policy appropriate and sufficiently clear? See comments attached

Q 18: Are the requirements on the ex post risk adjustments appropriate and sufficiently clear? NA

Q 19: Are the requirements in Title V sufficiently clear and appropriate? NA

Q 20: Are the requirements in Title VI appropriate and sufficiently clear? NA

Q 21: Do institutions, considering the baseline scenario, agree with the impact assessment and its conclusions? NA

Q 22: Institutions are welcome to provide costs estimates with regarding the costs which will be triggered for the implementation of these guidelines. When providing these estimates, institutions should not take into account costs which are encountered by the CRD IV provisions itself. NA

Contact name Silvia Frömbgen