AIFMD: Remuneration

The FCA’s Quarterly Consultation CP14/4 proposes to introduce guidance on SYSC 19C (BIPRU Remuneration Code) to the effect that an AIFM that is also a BIPRU firm that complies in full with SYSC 19B (AIFMD Remuneration Code) will not have to demonstrate compliance with SYSC 19C.

The above may look familiar and it may have been assumed that this Guidance already existed. It certainly used to, pre-CRD IV, when SYSC 19 only comprised two chapters: SYSC 19A for BIPRU firms and SYSC 19B for AIFMD firms. However when SYSC 19 was revised into three chapters as a result of CRD IV, the above Guidance disappeared so its re-introduction is to be welcomed. The precise wording can be found in Appendix 2, Annex B of the consultation paper. It is noted that CP14/4 does not propose adding any similarly worded Guidance for those AIFMs that fall under IFPRU.

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