The rule in plain words
Highest amount of severance payments awarded in year N to a single person cannot be more than severance payments awarded in year N – total amount.
EBA checks it for four columns: MB supervisory function, MB management function, other senior management and other identified staff. That makes four 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.
Other senior management: Highest amount of severance payments awarded in year N to a single person <= Severance payments awarded in year N – total amount
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 02.01 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 remuneration of identified staff in investment firms (R 02.01)
Rows
- 0340Severance payments awarded in year N – total amount
- 0370Highest amount of severance payments awarded in year N to a single person
Columns
- 0010MB Supervisory function
- 0020MB Management function
- 0090Other senior management
- 0100Other identified staff
A worked example
The first of its checks, with simple numbers.
Severance payments awarded in year N – total amount 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_02.01,r0370,c0090,} <= {R_02.01,r0340,c0090,}The next three:
{R_02.01,r0370,c0100,} <= {R_02.01,r0340,c0100,}{R_02.01,r0370,c0010,} <= {R_02.01,r0340,c0010,}{R_02.01,r0370,c0020,} <= {R_02.01,r0340,c0020,}Other rules on R 02.01
- If severance payments awarded in year N, number of beneficiaries is reported, highest amount of severance payments awarded in year N to a single person must be reported (v12614_m)Warning
- Severance payments awarded in year N: if total amount is reported, number of beneficiaries must be reported (v12613_m)Warning
- Severance payments awarded in year N: if number of beneficiaries is reported, total amount must be reported (v12612_m)Warning
- Number of identified staff (headcount) must equal members (headcount) (row 0010, v12618_m)Warning
- Guaranteed variable remuneration in year N: if total number of beneficiaries is reported, total amount must be reported (v12611_m)Warning
- Variable remuneration, total must equal the sum of its four parts (v12619_m)Warning
- Guaranteed variable remuneration in year N: if total amount is reported, total number of beneficiaries must be reported (v12610_m)Warning
- For investment firms that do not benefit from the derogation under Article 32(4)(a) at an institutional level Thereof: variable remuneratio cannot be more than total variable remuneration in year N (v12606_m)Warning
Every REM benchmarking (IF) rule, by template
Checks like this one, run at the point of submission, are the first step to real-time supervision.