The rule in plain words
Severance payments awarded during the financial year – number of high earners cannot be more than total number of high earners.
EBA checks it for nine columns, from MB supervisory function (0010) to all high earners in investment firms that are subject to Articles 25 and 34 of Directive 2019/2034 (0090). That makes nine checks. A failure names the one that failed.
How the Line4 Check report words itShowHide
The first of its checks, word for word as the report shows it when it fails. The others read the same, with their own column, row or sheet.
Corporate functions: Severance payments awarded during the financial year – Number of high earners <= Total number of high earners
What to do if your filing fails it
- 01Open the template below and find the cells the rule reads.
- 02Compare the values in your file. If the first is bigger than it may be, one of them is wrong: check both before you change either.
- 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
- 04It runs only when your filing indicators mark R 04.00 as reported.
- 05This is a warning. It does not stop the filing on its own, but your authority may ask you to explain it.
The cells it reads
Information on the remuneration of high earners (I) (R 04.00.a)
Rows
- 0040Total number of high earners
- 0190Severance payments awarded during the financial year – Number of high earners
Columns
- 0010MB Supervisory function
- 0020MB Management function
- 0030Investment banking
- 0040Retail banking
- 0050Asset management
- 0060Corporate functions
- 0070Independent control functions
- 0080All other high earners
- 0090All high earners in investment firms that are subject to Article 25 and 34 of Directive 2019/2034
A worked example
The first of its checks, with simple numbers.
Total number of high earners must then be at least 1,200.
A file that reports 1,200 passes. One that reports 1,100 fails, by 100.
The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.
Show the rule as writtenShowHide
EBA's formula, as written out for the first of its checks. Cells are written as {template, row, column, sheet}.
{R_04.00.a,r0190,c0060,} <= {R_04.00.a,r0040,c0060,}The next five:
{R_04.00.a,r0190,c0070,} <= {R_04.00.a,r0040,c0070,}{R_04.00.a,r0190,c0080,} <= {R_04.00.a,r0040,c0080,}{R_04.00.a,r0190,c0040,} <= {R_04.00.a,r0040,c0040,}{R_04.00.a,r0190,c0090,} <= {R_04.00.a,r0040,c0090,}{R_04.00.a,r0190,c0010,} <= {R_04.00.a,r0040,c0010,}And 3 more, the same formula for the other cells it covers.
Other rules on R 04.00.a
- Severance payments awarded during the financial year, total amount cannot be more than total variable remuneration of all high earners (v09266_m)Warning
- Total amount of contributions to discretionary pension benefits in year N cannot be more than total variable remuneration of all high earners (v09267_m)Warning
- Total amount of variable remuneration awarded for multi- year periods under programmes which are not revolved annually cannot be more than total variable remuneration of all high earners (v09268_m)Warning
- Severance payments awarded during the financial year: if total amount is reported, number of high earners must be reported (row 0200, v09269_m)Warning
- The sum of three rows cannot be more than total variable remuneration of all high earners (v09282_m)Warning
- MB management function cannot be negative (v09240_s)Warning
- None of the 72 values it checks in information on the remuneration of high earners (I) can be negative (v09239_s)Warning
- If a sum of five rows is zero or more, total variable remuneration of all high earners cannot be negative (v09293_m)Warning
Every REM high earners rule, by template
Checks like this one, run at the point of submission, are the first step to real-time supervision.
