Remuneration Code Follow-up

Firms should now be ‘broadly compliant’ with most of the Remuneration Code Principles in keeping with section 4.6 of PS10/20 ‘Revising the Remuneration Code’ – see Regulatory Roundup 24 which also includes a link to PS10/20.

The one exception is Principle 12 (‘Remuneration Structures’) where firms coming into scope for the first time can take advantage of transitional provisions where compliance is required by 1 July 2011 at the latest (although Tier 3 & 4 firms can disapply several elements of Principle 12).

Firms are reminded that where any shortfalls are identified, a time specific plan to rectify them should be in place by the end of January.

It is also worth bearing in mind that the FSA will be sending out to all firms in scope a data return that will require firms to certify that they are compliant with the Code, as well as various data on remuneration policies and practices (see section 4.7 and onwards of PS10/20).Note that we are told that the FSA will review the data to determine whether anything might ‘warrant further investigation’ .It is expected that firms will be asked to supply this data during the second half of 2011.