dfsa s remuneration thematic review key findings 2013
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DFSAs Remuneration Thematic Review Key Findings 2013 Agenda Quick - PowerPoint PPT Presentation

DFSAs Remuneration Thematic Review Key Findings 2013 Agenda Quick Background Detailed Findings DFSAs Expectations Governance Structures Introduction Remuneration Report 2013 Background - Participation 145


  1. DFSA’s Remuneration Thematic Review Key Findings 2013

  2. Agenda • Quick Background • Detailed Findings • DFSA’s Expectations – Governance – Structures

  3. Introduction – Remuneration Report 2013

  4. Background - Participation 145 Subsidiaries /startups 221 80% 76 Branches

  5. 221 Background - Participation 80% 120 Arrangers and Advisers 100 80 Asset Management/Agency Trading 60 40 Full Scope Banking Services Lending/Principal Trading 20 Insurance/Reinsurance 0

  6. 221 Key Findings 80% 28% consider remuneration a key risk category

  7. 221 Governance -Remuneration Policy 80% 66% of the respondents said that they have a remuneration policy 26% 24% 22% 19% Have a committee meet annually take minutes report to the board

  8. 221 Controls 80% 28% consider remuneration a key risk category have a committee Meet annually Report back to the Take minutes Board 90% 85% 82% 80% 89% Involve the Risk Officer 90% Involve the Compliance Officer

  9. 221 Controls 80% 26% involve the 25% involve the Compliance Officer Risk Officer 25% 26% 74% 75%

  10. Controls Compliance Officer Risk Officer 0% 25% Insurance/Reinsurance Insurance/Reinsurance 27% 25% Arrangers and Advisers Arrangers and Advisers Asset Asset Management/Agency 32% 32% Management/Agency Trading Trading 21% 26% Lending/Principal Trading Lending/Principal Trading Full Scope Banking Full Scope Banking 13% 17% Services Services 0% 20% 40% 0% 20% 40%

  11. Controls We highly encourage Firms to: 1) consider remuneration as a key risk activity 2) Include compliance and risk in formulation of the remuneration policy 3) Include remuneration activities in the management reporting pack

  12. 221 Key Findings 80% 76% Fixed Variable

  13. 221 Key Findings: Current Risks 80% Variable components of the compensation was not always clearly defined and the remuneration policy did not always include key individuals. Treat staff holding various functions differently 49% treat individual products differently 18%

  14. Key Findings: Future Risks The overall remuneration of staff lacked a long term view performance contains deferred compensation scheme 42% have claw-back arrangements 34% 14% have separate claw-back provisions for DIFC

  15. Key Findings Strategic targets 62% Investors satisfaction Considered other non financial Effective risk management criteria Effective compliance

  16. Controls We highly encourage Firms to: 1) Consider other non financial criteria when evaluating performance 2) Consider the long term view performance 3) The risk associated with the variable components

  17. DFSA Expectations – Principle 12 “An Authorised Firm must have a remuneration structure and strategies which are well aligned with the long term interests of the firm, and are appropriate to the nature, scale and complexity of its business” – GEN 5.3.31 (1) Remuneration Structure and Controls – GEN A3.2 Guidance Best practices related to remuneration (development of structure, policy, performance assessment)

  18. DFSA Expectations • Development and monitoring of remuneration – Responsibility of the Governing Body – Remuneration Committee – Reflected in a documented policy – Consistent application

  19. DFSA Expectations • Documented Remuneration Policy – Appropriate to the firm’s business and size of risk – All staff and directors to be covered by the policy – Formulated with involvement of key stakeholders, including Compliance and Risk functions – Discussed and approved by the Governing Body – Reviewed and updated regularly

  20. DFSA Expectations • Risk-sensitive Compensation Framework – Separate bonus pools for risk-takers and control functions – Performance assessments – Where appropriate, long-term horizon for performance-based awards – Use of variable vs fixed components

  21. DFSA Expectations • Disclosure requirement GEN 5.3.31 – Must be approved by the Board of the Authorised Firm – In a format that is available to the DFSA.

  22. Conclusion • Thank you for participation • Remuneration “Business as Usual” • Future Thematic surveys

  23. Thank You

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