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Remuneration
The CRD requires credit institutions to have arrangements, strategies, processes and mechanisms to manage the risks to which they are exposed and requires competent authorities to review them and to determine whether the own funds held by the credit institution or investment firm ensure a sound management and coverage of the risks to which the institution or firm is or might be exposed.
The changes to the CRD regarding remuneration suggest that remuneration policies should be among these internal practices covered by the Directive, requiring financial institutions to have “remuneration polices and practices that are consistent with and promote sound and effective risk management”. In the Annex is a list of principles on remuneration that companies should apply to.
However, the principles listed only constitute a part of the principles outlined in the recent Recommendation on financial remuneration. In its submission, UNI Europa Finance has pointed out to the Commission that the principles in the Annex should cover the entire Recommendation or at least make reference to it in the Directive.
Trading book and re-securitisations
The Commission suggest, among other things strengthening the capital requirements in the trading book and raising capital charges for certain securitisation exposures.
In its submission, UNI Europa Finance welcomes the proposed changes, which will result in a stronger solvency position of banks and make them more stable to the benefit of customers and employees in the banks. UNI Europa Finance has furthermore provided comments and assessments of specific suggestions as requested in the consultation document.