Invest Europe-PAE

Response to EBA Consultation on IFD-R Level 2 measures

Positions & consultation responses

04 Sep 2020

This response calls the EBA to introduce targeted changes to some of its technical measures to implement the prudential and remuneration rules that apply to MiFID investment firms (and which could create a precedent in an AIFMD context). Areas on which this response focuses include double-counting of assets when determining the firm’s capital requirements, the staff that is deemed to have a material impact on the firm’s risk profile and alternative arrangements that may be used to pay variable remuneration.