EBA has published its final draft RTS on the criteria to define material risk takers for CRD purposes. It has published the revised standards to define and harmonise the criteria across the EU. An individual member of staff would be considered to have a material impact on the institution’s risk profile as soon as they meet at least one of the criteria – which will be laid down in a combination of the CRD, the RTS (which includes both qualitatitve and quantitative criteria) or additional internal criteria necessary and bespoke to an institution’s business model.
In terms of quantitative criteria, the revised CRD sets a total remuneration of €500,000 combined with the average of the remuneration of management body members and senior management. In terms of quantitative criteria, these need to recognise proportionality and the different hierarchical levels in institutions of different sizes. The qualitative criterion also include levels of remuneration above €750,000 and the top 0.3% of staff in institutions with over 1,000 staff.