Emma RadmorePRA has published an update on the requirements applicable to material risk takers. The EU did not adopt an updated version of the MRT Regulation before the transposition date of CRD V, and so PRA is currently using the June 2020 EBA draft as the basis for the application of the Remuneration Part of its Rulebook. But as it has previously explained this means there is a discrepancy between the RTS that continue to apply in UK law and the draft that applies in relation to the Rulebook.
PRA will consult on updating this position but, in the meantime:
- firms must continue to comply with MRT RTS 604/2014 and must also apply the draft MRT RTS when determining which individuals the Remuneration Part applies to;
- the new draft will generally mean firms will identify more relevant individuals, so PRA thinks that in complying with the draft RTS firms will also comply with the “old” ones; and it also thinks that firms need not apply the Remuneration Part to any individuals who would meet the “old” but not the draft criteria;
- PRA reminds firms that the draft RTS are a minimum standard;
- PRA is working on a review of templates and notes that firms may apply for a waiver for excluding certain MRTs; and
- Firms with a fiscal year end of 31 December may have until 30 September to submit the PRA required tables – but only for one year.
