SUP 16 Annex 34B Guidance notes for data items in SUP 16 Annex 34AR
(1) Financial year for which the remuneration is awarded
A firm's financial year should be designated by reference to the calendar year in which it ends. For example, if a firm's accounting reference date is 31 March 2013, the financial year that begins on 1 April 2013 and ends on 31 March 2014 will be the firm's 2014 financial year.
(2) Consolidation
When reporting on a consolidated basis as a UK lead regulated group, firms should where possible treat the consolidation group as a single entity (i.e. line-by-line) rather than on an aggregation basis.
(3) Currency
See SUP 16.17.4R (9) which provides that firms must report in euros. To convert into euros, firms must use the rates published by the European Commission for financial programming and budget for December of the reported year. The table is published on the European Commission’s website: http://ec.europa.eu/budget/contracts_grants/info_contracts/inforeuro/inforeuro_en.cfm
The table contains monthly exchange rates. A list sorted by country name can be generated using the ‘access by list of countries’ function. Institutions should use the exchange rate applicable for the month in which the financial year ended.
Figures should be reported in full amounts.
(4) Information to be collected
(a) High earners should be classified under the EEA State, function or business area and responsibility where they carry out the predominant part of their business activities. The full amount of remuneration awarded to the relevant high earner within the group or firm should be reported under this EEA state, function or business area and responsibility.
(b) If the predominant areas for one high earner have the same weight, the firm should allocate the high earner and his remuneration taking into account the allocation of other high earners, so that the report best reflects the distribution of high earners within the firm.
(c) For each high earner, figures should only be reported once and the full amounts should be assigned to one EEA state, one function or business area and responsibility only.
(d) High earners who carry out professional activities both within and outside the EEA should be classified under an EEA state only if they carry the predominant part of their professional activities within the EEA. Otherwise, figures should not be reported.
(5) Data elements
These are referred to by row first and then by column, so data element 2B will be in row 2 and column B.
(6) Separate templates
Firms should submit a separate template for each EEA Member State where the group is operating.
(7) Definitions
For the purpose of completing the form in SUP 16 Annex 34A, the following terms are defined:
Term
Definition
MB Supervisory Function
Members of the management body in its supervisory function; this includes non-executive directors of any board in the scope of consolidation.
MB Management Function
Members of the management body in its management function who have executive functions within the management body; this includes all executive directors of any board in the scope of consolidation.
Investment Banking
Include corporate finance advice services, private equity, capital markets, trading and sales.
Retail Banking
Include total lending activity (to individuals and enterprises).
Asset Management
Include portfolio management, managing of UCITS and other forms of asset management.
Corporate Functions
All functions that have responsibilities for the whole institution at the consolidated level and for subsidiaries with such functions at the solo level, e.g. Human Resources, IT.
Independent Control Functions
Staff active in the independent risk management, compliance and internal audit functions as described in the EBA’s guidelines on internal governance. Such reporting requirements should apply to these functions at the consolidated level and for subsidiaries with such functions at the solo level.
All Other
This column should include staff that cannot be allocated to one of the designated business areas.
Senior management
As defined in the Glossary, that is those persons who are a natural person and who exercise executive functions in an institution and who are responsible and accountable to the management body for the day-to-day management of the institution.
Control Functions
Control functions comprise control functions within the business units and the independent compliance, risk control and internal audit function.
High Earners
As defined in the Glossary, that is an employee whose total annual remuneration is EUR 1 million or more per year or its equivalent in another currency determined by reference to the conversion rate applicable to the corresponding High Earners Report under SUP 16.
Identified Staff
Staff whose professional activities have a material impact on the firm's risk profile in accordance with Regulation (EU) 604/2014 (Regulatory technical standards to identify staff who are material risk takers). For data relating to the performance year 2013, identified staff are those whose professional activities have a material impact on the firm's risk profile in accordance with SYSC 19A.3.4 R.
Fixed remuneration
Fixed remuneration includes payments, proportionate regular (non-discretionary) pension contributions or benefits (where they are without consideration of any performance criteria).
Variable remuneration
Variable remuneration includes additional payments or benefits depending on performance or, in exceptional circumstances, other contractual elements but not those which form part of routine employment packages (such as healthcare, childcare facilities or proportionate regular pension contributions). Both monetary and non-monetary benefits should be included. Amounts should be reported gross, without any reduction due to the application of the discount rate for variable remuneration for the categories of total variable remuneration, variable in cash, variable in shares and share-linked instruments, and variable in other types of instruments.
Variable remuneration in other types of instruments
Deferred variable remuneration in other types of instrument
Instruments in accordance with Commission Delegated Regulation (EU) No 527/2014 (Regulatory technical standards specifying the classes of instruments that adequately reflect the credit quality of a firm as a going concern and are appropriate to be used for the purposes of variable remuneration).
Deferred remuneration
Should be determined with reference to SYSC 19A.3.49 R. Amounts should be reported gross, without any reduction due to the application of the discount rate for deferred variable remuneration for the categories of total deferred variable remuneration, deferred variable in cash, deferred variable in shares and share-linked instruments, and deferred variable in other types of instruments.
Discretionary pension benefits
As defined in the Glossary with reference to article 4(1)(73) of the EU CRR, which means enhanced pension benefits granted on a discretionary basis by a firm to an employee as part of that employee's variable remuneration package, which do not include accrued benefits granted to an employee under the terms of the company pension scheme.
(8) Specific guidance on data fields
Field
Guidance
3B
Payment bracket
Figures should be provided within value brackets of EUR 1 million (e.g. EUR 1 million to less than EUR 2 million, EUR 2 million to less than EUR 3 million etc.).
Business Areas
4A-6H
Individuals
The numbers of staff in the categories should be expressed in full time equivalents (FTEs) and be based on year-end numbers.
9A-16H
Fixed remuneration
Variable remuneration
Deferred fixed and variable remuneration should not be included in these fields.
17A-20H
Deferred remuneration
Includes deferred variable remuneration.
Additional information regarding the amount of total variable remuneration
22A-H
Severance payments
The total monetary value of severance payments in the financial year.
24A-H
Variable remuneration for multi-year periods which are not revolved annually
Remuneration awarded based on multi-year accrual periods that do not revolve on an annual basis, i.e. where institutions do not start a new multi-year period every year, should be fully allocated to the performance year in which the remuneration was awarded, without consideration of the point in time when the variable remuneration is effectively paid. These amounts should be reported separately to allow a further analysis of fluctuations of the variable remuneration and should not be deducted from the amount of variable remuneration reported.
Supplementary Information
25A
Staff categorised as ‘all other’
For staff included in column H ‘all other’, institutions must provide explanatory text including the business area in which those staff sit.