The Financial Stability Board (FSB) published a progress report on the implementation of its principles for sound compensation practices and their implementation standards in financial institutions. The report covers practices of the largest financial institutions in the banking, insurance, and asset management sectors. It highlights uneven progress toward implementing the principles and the standards, with banks relatively more advanced than insurance and asset management firms. This likely reflects the more pressing need for banks to align compensation with risk-taking, following the 2008 global financial crisis.
Against this backdrop, the report focuses on:
- The effectiveness of compensation frameworks. A common approach to assess employee performance and determine variable compensation is to use a balanced scorecard based on key performance indicators, complemented by other inputs. The report notes that it is critical to establish and apply such a framework to promote a sound risk culture in a firm. While in-year adjustments and malus are commonly used, the use of clawback is not widespread due to ongoing legal and practical constraints. The report advocates incorporating clawback terms and severance clauses in employment contracts to enhance their enforceability and effectiveness.
- Emerging trends. Non-financial measures and disclosure of compensation-related information are increasingly used to shape and promote a sound risk culture and positive behaviors, as well as to contribute to robust risk management. Firms are increasingly incorporating environmental, social, and governance (ESG) aspects to drive accountability for delivering outcomes. This must be underpinned by robust governance, as the increasing application of non-financial measures requires the Board and internal control functions to use discretion and judgement appropriately.
- Experience during the COVID-19 pandemic. The report finds that most existing compensation frameworks, and associated governance mechanisms, have demonstrated sufficient flexibility to date. However, while banking authorities in most jurisdictions have powers to direct firms to hold back and/or limit bonuses, especially in cases where there are concerns about capital conservation, or to increase deferral periods, this is much less prevalent in the asset management and insurance sectors.
Keywords: International, Banking, Insurance, Securities, Compensation Practice, Remuneration, Governance, ESG, COVID-19, Operational Risk, FSB
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